ML20071N148
| ML20071N148 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/31/1983 |
| From: | Norton B NORTON, BURKE, BERRY & FRENCH, PACIFIC GAS & ELECTRIC CO. |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8306060275 | |
| Download: ML20071N148 (630) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )
) Docket No. 50-275 PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-323
)
Diablo Canyon Nuclear Power Plant )
Units Nos. 1 and 2 )
)
RESPONSE OF PACIFIC GAS AND ELECTRIC COMPANY TO MOTIONS TO REOPEN THE RECORD ON CONSTRUCTION QUALITY ASSURANCE FILED BY JOINT INTERVENORS AND GOVERNOR DEUKMEJIAN N_/
ROBERT OHLBACH PHILIP A. CRANE, JR.
RICHARD F. LOCKE Pacific Gas and Electric Company P.O. Box 7442 San Francisco, California 94120 (415) 781-4211 ARTHUR C. GEHR Snell & Wilmer 3100 Valley Center Phoenix, Arizona 85073 (602) 257-7288 i
BRUCE NORTON l Norton, Burke, Berry & French, P.C.
P.O. Bcx 10569 '
Phoenix, Arizona 85064 (602) 955-2446 Attorneys for Pacific Gas and Electric Company O DATED: May 31, 1983.
0306060275 830531
O 1 TABLE OF CONTENTS ,
2 Page 3
I INTRODUCTION . . . . . . . . . . . . . . . . . 1 4
II THE RECORD IN THIS PROCEEDING SHOULD NOT 5 BE REOPENED FOR CONSIDERATION OF CON-STRUCTION QUALITY ASSURANCE . . . . . . . . . . 2 6
A. Overview . . . . . . . . . . . . . . . . . 2 7
B. The Tennyson / Roam Statement Does Not 8 Provide Significant New Evidence Which Would Lead To A Different Result . . . . . 9 9
C. The Independent Design Verification 10 Program's Interim Technical Reports Nos.
36 And 38 Provide Further Assurance That 11 Construction Quality Assurance At Diablo Canyon Was Adequate And Do Not Provide 12 Significant New Evidence Which Would Lead To A Different Result . 45
({ }
D. The Alleged "As-Built" Deficiencies Are 14 Not Evidence Of Deficiencies In Con-struction Quality Assurance . . . . . . . 65 15 E. Past Design Quality Assurance Deficien-16 cies Are Not Significant New Evidence of Construction Quality Assurance Defi-17 ciencies Which Would Lead To A Different Result . . . . . . . . . . . . . . . . . . 67 18 F. Construction Quality Assurance Is Being 19 Closely Adhered To In Ongoing Construc-tion . . . . . . . . . . . . . . . . . . . 76 20 III THERE IS NO LEGAL BASIS TO REOPEN THE 21 RECORD FOR THE TAKING OF EVIDENCE ON CONSTRUCTION QUALITY ASSURANCE . . . . . . . . 80 22 A. The Motion Does Not Address A Signifi-23 cant Safety Issue Nor Would The
" Evidence" Supplied By Movants Lead To A 24 Different Result . . . . . . . . . . . . . 80
/~N 25 B. Should The Record Be Reopened On Con-Og,) struction Quality Assurance An Undue And 26 Prejudicial Delay Will Result . . . . . . 82
-i-
l 1
0 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3
4 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 5
6 7
In the Matter of )
8 ) Docket No. 50-275 PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-323 9 )
Diablo Canyon Nuclear Power Plant )
10 Units Nos. 1 and 2 )
)
11 12 RESPONSE OF PACIFIC GAS AND ELECTRIC COMPANY TO MOTIONS TO REOPEN THE RECORD ON CONSTRUCTION 13 QUALITY ASSURANCE FILED BY JOINT INTERVENORS AND GOVERNOR DEUKMEJIAN 14 15 I 16 INTRODUCTION ,
17 On April 21, 1983 the Atomic Safety and Licensing 18 Appeal Board in this proceeding (Appeal Board) issued a 19 Memorandum and Order reopening the record on the issue of 20 design quality assurance. If The Appeal Board declined to 21 rule on the issue of construction quality assurance and, 22 instead, invited the Joint Intervenors and the Governor to 23 24 1./ In the memorandum and order the Appeal Board expressed its concurrence with the PGandE and Staff position that 25 the motions previously filed met the standards for (0
26 opening closed records as far as design quality assur-ance was concerned.
(O f 1 refile their motions to reopen the record on this matter.
2 The Joint Intervenors filed their motion on May 10, 1983 and 3 the Governor filed his motion on May 17, 1983. Pursuant to 4 stipulation of the parties 2f PGandE herewith files its 5 single response to the two motions on the day its response 6 to the Governor's motion is due.
7 II 8 THE RECORD IN THIS PROCEEDING SHOULD NOT BE REOPENED FOR CONSIDERATION OF CON-9 STRUCTION QUALITY ASSURANCE.
10 A. Overview 11 The Construction Quality assurance programs on the 12 Diablo Canyon project have been vigorous, thorough and in (O' 13 full compliance with NRC regulations. They have been 14 subjected to comprehensive and frequent inspections and l
15 audits by the licensee, contractors and NRC personnel.
16 Nevertheless, possibly due to lack of experience in 17 construction quality assurance and great reliance on the 18 advice of Richard B. Hubbard y (former consultant to former j 19 ///
20 2f iiorton letter to Appeal Board dated May 24, 1983.
21 y A careful review of Mr. Hubbard's statement of qualifi-22 cations appended as Attachment A to his affidavit of May 24, 1982, clearly reflects that he has had :ao for-23 mal experience, background or training, in construction quality assurance matters. This lack of experience may 24 well explain his basic failure to understand the con-struction QA process in general and, more importantly, 25 his inability to recognize the relative insignificance tO 26 of the Tennyson / Roam items or the significance of the IDVP construction quality assurance review results.
(
O 1 Governor Brown, who was an avowed opponent to operation of 2 Diablo Canyon in any time frame) the Governor and Joint 3 Intervenors have filed motions to reopen the record on 4 construction quality assurance.
5 As factual support for their motions both the 6 joint intervenors and the Governor continually mischaracter-7 ize or misinterpret many of the operative facts, myopically 8 distill from these facts unsupported conclusiens and 9 generally create a misleading impression regarding 10 construction quality assurance at Diablo Canyon.
11 The Movants base much of their argument on l
l.
I % 12 inferences drawn from circumstantial evidence or pure g
13 speculation based on statements capable of multiple 14 interpretations. Movants even attempt to create negative 15 inferences from facts and evidence that support PGandE's 16 contention that construction activities have met, and 17 continue to meet, quality requirements. If reduced to the 18 actual evidence of deficiencies in construction quality 19 assurance (CQA) the motions would be several pages, as 20 opposed to several inches, and would provide this Board with 21 a clear opportunity to view the question which is really 22 before them. That question is whether a closed record l 23 should be reopened for a new contention based on normal 24 occurrences in the construction of a nuclear power plant.
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O 1 The plethora of references to unrelated facts and 2 events with the apparent intention of creating misleading 3 and inappropriate inferences is easily illustrated by 4 reviewing the discussion at p. 6 of the Governor's Motion.
5 There, after discussing construction quality assurance 6 issues in the Midland case, the text deftly slips into a 7 discuss. ion of Mr. Williams Dircks' testimony before Congress 8 on November 19, 1981. The obvious and intended implication 9 is that Diablo Canyon was a plant with construction QA 10 problems being referenced by Mr. Dircks. In point of fact 11 Dircks' testimony concerning Diablo Canyon was restricted 12 solely to a discussion of design QA matters. (Dircks 13 Testimony, Oversight Hearing, House of Representatives, 14 Nov. 19, 1981, Serial No. 97-26, pp. 9-10.) Any and all 15 testimony regarding contruction quality assurance given that 16 day, including Dircks', concerned facilities other than 17 Diablo Canyon. As we will show in succeeding portions of 18 this Reply, Pacific Gas and Electric Company had, and 19 continues to have, in place a functioning and acceptable 20 construction quality assurance program at Diablo Canyon.
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24 O '
26
, ~4-
1 In order to place these matters in perspective, a 2 brief recapitulation of the history of construction quality 3 assurance developments at Diablo Canyon is necessary. 4/ As 4 early as 1968 and 1969 there were quality control and 5 quality assurance requirements placed on manufacturers and 6 contractors for work at Diablo Canyon. Beginning in 1969, 7 prior to the effective date of 10 C.F.R. Part 50, Appendix B 8 (Appendix B), PGandE required each contractor to have a 9 quality assurance program qualified to meet PGandE and NRC 10 requirements. All contractors and subcontractors or 11 suppliers providing- Class I work or material adhered to 12 these procedures in the performance of work at the site or (O'd 13 any other location affecting materials or products 14 ultimately destined for the site.
15 All site activities were, except where 16 deficiencies were noted and corrected, conducted in 17 compliance with Appendix B requirements. Each contractor 18 was contractually required to prepare and staff site quality 19 assurance / quality control (QA/QC) organizations adequate to 20 inspect the quality of work performed. PGandE field i
21 engineers and inspectors then reinspected this work for 22 compliance with the applicable design documents and 1
23 l
24 4f This background information is discussed more fully in l PGandE's Response to Joint Intervenors' Motion to l 25 Reopen the Record and the supporting affidavits filed
. with this Board on July 2, 1982 at pp. 6-19 which are 26 incorporated by reference in this Response.
~
O 1 specifications. The general construction quality control 2 on-site group was then directly involved in the verification 3 of the adequacy and effectiveness of the contractors' 4 quality assurance program and the Company's following 5 inspections. Finally, corporate on-site quality assurance 6 engineers verified the adequacy and effectiveness of the
, 7 entire process.
8 PGandE commenced formal audits of construction 9 activities in December 1969 when the QA Engineering 10 Department was formed. Construction audits were conducted i
11 on a regular basis in accordance with NRC regulations as 12 described in the PGandE QA manual. The corporate 13 QA/ construction QC audits from 1969 to 1981 exceed 1500.
14 This total does not include the hundreds of additional 15 audits conducted by the contractors in accordance with their 16 QA programs or further audits and inspections by the NRC.
17 Nothwithstanding the sweeping generalizations and 18 unsupported innuendos and inferences drawn by Mr. Hubbard in 19 his affidavits and declaration, the record is clear that the 20 Nuclear Regulatory Commission construction inspection 21 Program was in place and functioning at Diablo Canyon. That l 22 Program placed great emphasis on assuring the quality of i
l 23 construction at Diablo Canyon over the years. Indeed Robert t
l 24 Engelken, Region V Administrator for many years prior to his l
25 retiren.ent in March 1983, specifically noted this fact at 26 the November 9, 1981 Commission Briefing stating that:
\
I T'"'" 7 = --, -?yy -.4m , _ , , , . _ , _ , _,_
l l
O 1 " Generally in inspecting the on-site l construction effort at the Diablo site 2 through the years it has been at least average and probably better than 3 average." (Tr. p. 23.)
4 While Mr. Hubbard has attempted to characterize 5 that effort as only a paperwork effort, the testimony of Mr.
6 Engelken at a Commission meeting on February 17, 1982 i
l 7 clearly contradicts that assertion. 5/
i i 8 9 5/ "Mr. Engelken: Harold [Denton], if I might. That's your recording right 10 there. I just want to point out we talked about --
Harold mentioned the i 11 record inspectors. It is true, we've had a resident at Diablo only for the 12 last 3-1/2 years, but we have a substan-tial effort -- in fact, the major part
, 13 of our [ construction] inspection effort has been from engineers from our region-14 al office and that inspection program goes far beyond just looking a (sic) 15 paperwork and looking at procedures. A very substantial part of that is ob-16 serving work and activities in progress and the records that we had examined, 17 materials certification, records of concrete testimony -- not only have we 18 witnessed the placement of the concrete we witnessed that we did examine proce-l 19 dures to see that the procedures that
! were being used in testing to determine l 20 the quality of the finished concrete were appropriate to allow the results to 21 be used in applying to checking the quality of concrete, but we examined 22 those records in some depth. We wit-nessed the testing itself and so, to
[as Hubbard did] that 23 characterize program as one as assuring that proce-24 dures are there is grossly misleading and that's the only point I want to make 26 [ footnote }/ continued on next page]
O As will be shown in the following material, the 1
2 Joint Intervenors and the Governor have not met the heavy 3 burden to justify the reopening of a closed record on the 4 issue of construction quality assurance. Specifically they 5 have not produced (1) significant new evidence relevant to 6 safety, which (2) if considered originally, would have 7 changed the result, and (3) done so in a timely manner.
8 (Kansas Gas and Electric C_o. (Wolf Creek Generating Station, 9 Unit 1) ALAB-462, 7 NRC 320 (1978); Pacific Gas and Electric 10 Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2),
11 CLI-81-5, 13 NRC 361 (1981). Further, reopening of the 12 record on this question will create an incredible delay i 13 which will unduly prejudice the licensee without further l
l 14 protecting the public health and safety.
15 5/ [ continued from previous page]
16 and I think the record will show the 17 efforts that I have mentioned as a substantial effort in observing and 18 verifying by experts in welding and concrete placement and other engineering 19 disciplines at the site. That's why we think that we have applied our major 20 effort, I'd say 95% or more of our inspection effort is devoted and has in 21 the past been devoted to site activi-ties. Through that program over a 22 period of ten years or more, we've gained a pretty fair competence in the 23 results' of our program, not revealing any substantial with the QA program. I 24 would point out also in this project, owner respresentation on site has far 25 exceeded the typical project, nuclear (O'
26 project, in my experience across the country." (Tr. p. 32-33.)
4 O
1 B. The Tennyson / Roam Statement Does Not Provide Significant New Evidence Which 2 Would Lead To A Different Result.
3 On April 5, 1983, deputy attorneys general Durbin 4 and Kaufman took the joint sworn statement of two former 5 employees of the Howard P. Foley Company, a major contractor 6 at Diablo Canyon. That statement is attached to the 7 Governor's Motion to Reopen as Exhibit B and is relied on 8 extensively by both Joint Intervenors and the Governor as 9 the cornerstone of their respective motions. Neither movant 10 saw fit to bring before the Board the earlier sworn 11 statement of Mr. Tennyson, taken by the NRC on March 25, 12 1983, which is attached to this response as Attachment 1.
O' 13 The March 25 statement gives the reader a significantly 14 different impression than does the April 5 statement. One 15 reasonable explanation for the difference is that the NRC 16 interviewers and the deponent both understood the subject 17 matter. As a result of the NRC's March 25 interview and the 18 sworn statement of April 5, the NRC, Region V, conducted a 19 special inspection. The results of that inspection are '
20 attached hereto as Attachment 2.
21 In essence the movants make nine arguments based 22 on the April 5 Tennyson / Roam statement. Those arguments 23 generally fall into one or more of the following categories:
24 Qualifications of QA/QC Personnel 25 (J. I. Mot. at 11; Gov. Mot. at 19; and Hub. Dec.
26 at 13.)
D
.(0 1 Ratio of Inspectors to Workers 2 (J. I. Mot. at 12.)
3 Preparation and Adequacy of Foley QA Program 4 (J. I. Mot. at 13; Gov. Mot. at 19, 21) 5 Nonconformance Documentation and Red Tag Removal 6 (J. I. Mot. at 12, 14; Hub. Dec. at 22) 7 Quality vs. Schedule 8 (J. I. Mot. at 12, 13; Hub. Dec. at 6) 9 Design Quality 10 (J. I. Mot. at 13; Gov. Mot. at 20; Hub. Dec. at i 11 20) 12 Inspector Harassment Q
13 (J. I. Mot. at 13, 14; Gov. Mot. at 20; Hub. Dec.
14 at 9) 15 Material Acceptance 16 (J. I. Mot. at 13; Hub. Dec. at 11) 17 Overtime Work 18 (J. I. Mot. at 13) 19 Each of these categories will be discussed, seriatim.
20 Qualifications of QA/QC Personnel 21 Movants cite several statements in the April 5 i
l 22 statement where Mr. Tennyson stated that until 1982 the 23 inspectors were not hired in accordance with "the ANSI 24 document or 10 CFR 50." Mr. Tennyson was on the job from 25 approximately 1974 to early 1983. Movants fail to discuss 26 even what the ANSI standards in question are or why what Mr.
I 1 Tennyson said about them might be important or, for that matter, how this relates to colistruction QA/QC. When one f
1 2
3 reviews what Mr. Tennyson told the NRC on March 25, 1983, 4 and the results of the NRC investigation, then it becomes
! 5 abundantly clear why the movants prefer the facts of the 6 matter to remain vague. Mr. Tennyson specifically stated i 7 inspectors were trained to properly do their jobs:
8 "Q. I see. Okay. That's . . .one of the items I wanted to get your profes-9 sional opinion on was the competency of the ins -- your inspection staff up un-10 til December '82. Did you feel that l
there were -- that the inspection staff 11 was competent up until that point, or l
did you feel otherwise?
12 A. [ Tennyson] I didn't really feel it 5 13 was incompetent because of the type of procedures that we working to. Our Procedures were reviewed in and accepted 14 by Pacific Gas and Electric Company who 15 was monitoring our quality program, and they were approved, the proce -- all 16 Procedures were approved by Pacific Gas
' and Electric Company prior to being in-l 17 stituted. So any inspection that was i done, if a -- we took some -- we did l 18 hire some inexperienced people, but they were indoctrinated and they were not l 19 turned loose in the field until we felt they -- they could perform their task 20 Properly and fill out their forms and
( document. But they were signing off l
21 their own inspections at the time we did i
turn them loose in the field on their 22 own." (Mar. Tr. at 67-68.)
23 Movants also fail to point out countervailing statements at other locations in the April 5 transcript. For example:
24 25 ///
26 ///
1
' j 1 "MS. DURBIN: Were you ever dissatis-fied, Mr. Tennyson, with the performance 2 of any of the employees that were pre-sented to you as opposed to the ones 3 that you had hired yourself, the ones i whose qualifications you really couldn't 4 check on?
5 I4R. TENNYSON: I don't think I could honestly answer that.
- 6 MS. DURBIN: Okay.
7 MR. TENNYSON: No more so than any of 8 some of the others I might have brought in myself." (Apr. Tr. at 17.)
9
. 10 "MR. TENNYSON: Well, we tried very hard
- 11 to set up a program and did have it set up to have a trainee inspector trained.
12 When I would bring a trainee in we would 13 put them with a qualified inspector, one that had been in the field enough times l 14 where we felt that they could handle their job properly out there and do the 15 procedure well enough.
16 We always tried to indoctrinate a new inspector or a trainee, you might say, 17 with the proper procedures and procedures that you would expect and put 18 them with a qualified person in the field until we felt they were ready to 19 go on their own in the inspection field." (Apr. Tr. at 13.)
20 21 "MR. TENNYSON: I was told numerous 22 times that we were not trying to hire I the inspectors in accordance with the 23 ANSI 4526 document or in accordance with 10 CFR 50 because we were not obligated, 24 evidently, to theH documents at that time." (AprT Tr. at 14, emphasTi add-25 ed.)
26 ***
(
1 Even more revealing are the results of the NRC 2 investigation:
3 " Concern: The concern was expressed or implied that H. P. Foley quality control 4 inspectors and quality assurance auditors were not qualified in accord-5 ance with ANSI N45.2.6, " Qualifications of Inspection, Examination, and Testing 6 Personnel for the Construction Phase of Nuclear Power Plants," and ANSI 7 N45.2.23, " Qualification of Quality Assurance Program Audit Personnel for 8 Nuclear Power Plants," respectively.
9 NRC Findings: This concern was not sub-stantiated.
10 To address this concern the inspectors 11 reviewed the qualification program for quality personnel working for the 12 Howard P. Foley Company. This examination indicated that the program
! (]n 13 or qualification of personnel was specified and controlled by H. P. Foley 14 Quality Control procedure QCP-6
" Indoctrination and Training," Revision 15 5.0, prior to December 1982.
16 This procedure specified the indor:trina-tion process and job-related t aining 17 requirements leading to certification as a fully qualified inspector. However, 18 this program did not specify levels of qualifications and educational require-19 ments, as required by ANSI N45.2.6, for quality control inspectors, and ANSI 20 N45.2.23, for quality assurance auditors. The inspector revi<wed the 21 licensee's quality assurance program that was in effect at the time (before 22 December 1982) and determined that ANSI N45.2.6 and N45.2.23, were not a commit-23 ment of the licensee's program and thus were never imposed on the contractors.
24 On May 4, 1981, the NRC issued generic letter 81-01 which required all li-f 25 censees of operating plants and holders
' of construction permits to endorse ANSI 26 N45.2.6 for quality control inspectors
r (O
1 and ANSI N45.2.23 for quality assurance auditors. The licensee responded in a 2 letter, dated July 14, 1981, and com-mitted to implement the above standards 3 with minor exceptions prior to full power licensing of Unit No. 1. In 4 August 1982, the licensee conducted a quality assurance audit (PGandE Audit 5 No. 20801) of the H. P. Foley Quality Assurance Program and an audit finding 6 was written against the H. P . Foley Quality Control / Quality Assurance Train-7 ing Program for inspectors and auditors.
In response to the audit findings, H. P.
8 Foley generated a new procedure (QCP-6A) for qualification and certification of 9 quality control inspectors and super-visors that fcllows the guidelines of 10 ANSI N45.2.6. In addition, a new pro-cedure has been drafted addressing the 11 qualification of quality assurance auditors in accordance with ANSI 12 N45.2.23.
13 The inspector reviewed the H. P. Foley qualification records for the Quality 14 Control Manager, Quality Control Inspec-tors, Supervisors, Quality Assurance 15 Auditors, Lead Auditors and the Quality Assurance Manager. Under the require-16 ments of H. P. Foley Quality Control Procedure QCP-6, in effect at that time, 17 the qualification records were satisfac-tory. However, a problem with imple-18 menting the new certification process required by the new procedure (QCP-6A) 19 was identified by the licensee. In late December 1982, the H. P . Foley Company 20 contracted with Cataract Engineering Company to supply additional quality 21 control personnel. These personnel were certified to a certain level by Cataract 22 based on experience and verified by an 8' investigative service. However, the
,23 resumes of the individuals, in some cases, did not support the certifica-24 tions in some areas. This problem was identified by licensee Quality Assurance 25 Audit No. 83043A, performed in February 1983, and further documented on Noncon-I
' hO 26 formance Report No. 8802-824, dated i
I
(
1 March 17, 1983. Currently the licensee, the H. P. Foley Company, and Cataract 2 Engineering Company are resolving the problem by verifying past employment of 3 the personnel in question. In the in-terim, personnel with a potential resume 4 problem are not being used in the field as quality control inspectors. This 5 nonconformance report (NCR No. 8802-024) l also notes that between December 7, 1982 t 6 and March 10, 1983, Level I inspection did not require a Level II co-signature, 7 and further notes that, "This noncon-formance encompasses both H. P. Foley 8 direct inspection personnel and sub-con-tracted, Cataract Engineering Company 9 personnel." The resolution of these licensee audit findings will be examined 10 during a future inspection. (50-275/
83-13-01) No items of noncompliance or I 11 deviations were identified." (Attach-ment 2 at 6-8.)
12
( As to the argument that inspectors had no prior 13 experience Mr. Tennyson admitted that he did not do the 14 hiring, and was not aware of the individuals' backgrounds:
15 "MR. KAUFMA". Did some of these people 16 have no previous construction back-ground?
17 l
MR. TENNYSON: It would be hard for me l 18 to say at this poi..t. Sometimes I l
didn't even see their application or j 19 resume or whatever, if they had one.
l
! 20 That went straight to the front office file and they were given to me to train 21 and make an inspector out of." (Apr.
Tr. at 14.)
.i 22 23 Ratio of Inspectors to Workers 24 The actual transcript quotes regarding this 25 allegation are as follows:
26 ///
,g 1 "MR. TENNYSON: During this time, speaking on this salary range here, 2 during the time the big push on the modifications came out there, we could 3 not hire inspectors nor make supervisors fast enough to cover the influx of weld-4 ing personnel, iron workers and other craftsmen that were in the field.
5 The quality department was so small 6 at that time. They were hiring a hun-dred, like a hundred or a hundred and 7 fifty a day of iron workers alone."
(Apr. Tr. at 20.)
8 9
"MR. ROAM: 1973 when I went there, I 10 think I was the fourth person. There was a manager, assistant manager, two or 11 three inspectors, something like that in 1973.
MS. DURBIN: Inspecting how many
- 13 people's work?
14 MR. ROAM: Well, at that time all we had was electrical. It must have been two 15 or three hundred electricians." (Apr.
Tr. at 23.)
16 s ***
17 Countervailing testimony from the transcript was neither 18 proffered nor cited by movants:
19 l
MR. TENNYSON: By the time the pro-20 duction forces came back to work [1974]
we pretty much had all our procedures 21 established and inspection criteria set up.
22 We had probably enough inspectors 23 at that time." (Apr. Tr. at 28.)
l 24 ***
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(
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1 The NRC investigation centered on the pre-1974 ratios and 2 found the following:
3 " Concern: The concern was expressed that the inspector-to-worker ratio was 4 inadequate prior to 1974.
5 NRC Findings: The concern was not sub-stantiated.
6 An examination of the H. P. Foley orga-7 nization and Quality Assurance / Quality Control manpower levels prior to June 4, 8 1974 indicated that there were 23 per-sons involved in quality assurance / qual-9 ity control functions during this peri-od. The organization consisted of four 10 supervisors, fifteen inspectors, and four clerks. According to the former 11 H. P. Foley Company employees (Refer-ence: State of California transcript, p 12 page 23) in 1973 the H. P. Foley Quality Department consisted of, "A manager,
. 13 assistant manager, and two or three inspectors." Based on the findings of 14 the NRC inspectors as noted above, this portion of the concern could not be 15 substantiated.
16 The testimony of the two former H. P.
Foley employees further indicates that 17 craft personnel during this period totaled, "two or three hundred electri-18 cians." Using these numbers, the in-spector-to-craft ratio (using 19 inspec-19 tors to 300 craft workers) would be 1:16. Interviews conducted with H. P .
20 Foley management indicated the inspector to craft ratio actually varied anywhere 21 from 1:10 to 1:20 during this period because of varying workload and the fact 22 that Quality Control Inspectors only examined Class I work, as opposed to 23 Class II work which received no quality control inspection. Class II identified 24 structures, systems and components which are not nuclear safety related.
25 f) iV Although the NRC has no regulations 26 regarding appropriate ratios of Quality
l<O 1 Assurance / Quality Control inspectors to craft personnel, the NRC did perform a 2 nationwide survey on this subject in
.; June 1981. The survey results were 3 inconclusive. The ratio of inspector to craft varied anywhere from 1:1.7 (WNP-2) 4 to 1:26 (Palo Verde). In addition to the contractor QA/QC organizations, the i
5 licensee maintains their own QA/QC orga-nization which provides for surveillance 6 and audit of contractor activities.
Furthermore, the licensee maintains a 7 staff of personnel, assigned to each of the Resident Electrical, Mechanical, '
8 Civil and Startup Engineers, who also provide for inspection and overview of 9 the work performed by site contractors.
These personnel further increase the 10 inspector / craft ratio.
! 11 The inspector considers that a substan-
! tial conclusion regarding the adequacy 12 of the inspector-to-craft ratio at Diablo Canyon during this period cannot 13 be established with certainty.
14 No items of noncompliance or deviations I were identified." (Attachment 2, at 15 19-20.)
16 There is no apparent concern regarding the ratio 17 of inspectors to workers from 1974 to late 1982. (Apr. Tr.
18 at 28. ) The increased construction at Diablo Canyon and the 19 resultant buildup in the work force began in December 1982.
20 (Affidavit of Bain, Manning and Etzler [ hereinafter BME 21 Aff.] at 10, attached hereto as Exhibit 1. ) During the 22 manpower buildup the ratio of non-manual to manual workers 23 has been maintained. (BME Aff. at 9.) During this same 24 period of time (from December 1982 to the present) the NRC 25 has increased their inspection activity approximately 80%
26 over that which was accomplished the prior year. (Ibid at l
(
i l
l l
(q v
i 1 11.) Between December 3, 1982 and May 20, 1983, the NRC i
l 2 conducted ten separate week long extensive inspections of l
3 construction activities including examination of procedures, 4 work process, final product and necessary documentation.
5 (Id.) In addition, PGandE has conducted over one-hundred 6 audits of construction activities during the past nine I
7 months. (Affidavit of Amaral at 1, attached hereto as 1
8 Exhibit 2.) All of these audits and inspections have 9 resulted in a relatively small number of findings which have 10 been corrected and are not indicative of " breakdowns in 11 construction QA," but rather what would reasonably be 12 expected from in excess of three and one half million
! 13 man-hours of work with strict construction QA/QC procedures.
14 (BME Aff. at 11, Amaral Aff. at 4-6.)
15 Preparation and Adequacy of Foley QA Program 16 Movants cite various portions of the April 5 i
( 17 statement to substantiate their generalized allegation that i
18 Foley did not "at any time" have a QA program which complied 19 with 10 C.F.R. Part 50. They do not however cite Messrs.
20 Tennyson and Roam when they testified as follows:
21 "MR. KAUFMAN: After 1974 when you were required to adopt a detailed quality 22 control program, what kind of a program did you adopt?
23 MR. TENNYSON: Well, in the b2 ginning, 24 right at the beginning we started establishing procedures in accordance 25 with the specifications, the PGandE specifications for building the plant.
26 (O !
1 MR. ROAM: And 10CFR50. " (Apr. Tr. at 27.)
2 3 Here, as in many other sections of the April 5 transcript, 4 it is not precisely clear whether the deponents understood 5 the questions, or, perhaps more importantly, whether the 6 deputy attorneys general understood the deponents' answers.
7 One familiar with construction quality assurance require-8 ments and the role of the Foley Company over the life of the 9 project would not arrive at the same totally negative 10 conclusions in propounding follow up questions nor in later 11 review of the transcript as do the movants. The negative 12 implications are far laore evident in the questions than in i
(?[ 13 the deponents' responses. The NRC investigation ascertained 14 the following:
15 " Concern: The concern was expressed or implied that H. P. Foley was not re-16 quired to comply with Title 10 of the l Code of Federal Regulations, Part 50 (10 l 17 CFR 50), Appendix B (Quality Assurance requirements).
18 NRC Findings: This concern was not sub-19 stantiated.
20 An examination of H. P. Foley's Quality Assurance Program history indicates that 21 H. P. Foley had a Quality Assurance Program in effect since September 4, 22 1970. On September 4, 1970, the Quality Assurance Manual for their first con-23 tract (Specification No. 8807) was ap-proved by Pacific Gas & Electric. The 24 program was developed using the criteria contained in the then recently issued 10 25 CFR 50, Appendix B. 10 CFR 50, Appen-60 26 dix B was issued by the AEC/NRC on June 27, 1970. The history of the
^
i l
Y,/N 1 contracts awarded to H. P. Foley, their areas of responsibility and the compli-2 ance of H. P. Foley's Quality Assurance to 10 CFR 50, Appendix B requirements up 3 to 1974 is further described in item Sq of this report.
4 On October 16, 1974, the U. S. Atomic 5 Energy Commission (AEC) issued their Safety Evaluation Report on the Diablo 6 Canyon Nuclear Power Station Units 1 and
- 2. Paragraph 17.4 of this report states 7 in part that:
8 "As a result of our detailed review and evaluation of PG&E's QA Program 9 description contained in Section 17.2 of the FSAR and a series of 10 discussions and meetings with the applicant, we conclude that the QA 11 organization of PG&E has sufficient '
independence and authority to ef-fs 12 fectively conduct the QA Program b without undue influence from those 13 organizational elements responsible for cost and scheduler."
14 In addition, Supplement No. 3 to the 15 Safety Evaluation Report, dated Septem-ber 18, 1975, in paragraph 17.3 states, 16 in part, that:
17 "The quality assurance program for plant operation of Diablo Canyon, 18 Units 1 and 2, complies with the guidance contained in WASH-1283 19 (May 24, 1974), " Guidance on Quali-ty Assurance Requirements During 20 Design and Procurement Phase of Nuclear Power Plants - Revision 1";
21 WASH-1284 (October 26, 1973),
" Guidance on Quality Assurance 22 Requirements During the Operations Phase of Nuclear Power Plants"; and 23 WASH-1309 (May 10, 1974), " Guidance on Utility Assurance Requirements 24 During the Construction Phase of Nuclear Power Plants." This com-25 plies with our position on the im-plementation of guidance in quality 26 assurance programs and is, there-fore, acceptable.
1 Based on our evaluation as des-cribed in the Safety Evaluation 2 Report and supplemented in this report, we now conclude that the 3 Diablo Canyon Quality assurance Program has the necessary controls 4 to comply with the requirements of Appendix B to 10 CFR Part 50 and 5 is, therefore, acceptable for con-trolling the operational phase of 6 Diablo Canyon, Units 1 and 2."
7 Pacific Gas and Electric Company, in Chapter 3, paragraph 3.2.1, of the Final 8 Safety Analysis Report (FSAR), states that:
9
" Appendix B to 10 CFR 50, " Quality 10 Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing 11 Plants," requires that structures, systems, and components important 12 to safety be designed and con-structed in accordance with the (c'd 13 quality assurance requirements described in Appendix B. There-14 fore, as described in Chapter 17 of the FSAR, the requirements of the 15 Diablo Canyon Quality Assurance Program apply to all structures, 16 systems, and components classified as Design Class I, this assures 17 that plant features important to safety have met the requirements of 18 Appendix B."
19 Chapter 17, of the FSAR states in para-
',* graph 17.1.2 that:
20
" Pacific Gas and Electric Company's 21 Quality Assurance Program requires that all contractors and suppliers 22 of Design Class I items establish and maintain in effect quality as-23 surance programs appropriate to the importance of their activities im-24 portant to safety. Requirements for contractors' and suppliers'
. 25 quality assurance programs are
!- prescribed in design specifica-26 tions. Specified requirements are O
1 based on 10 CFR 50, Appendix B.
Contractors and suppliers are not 2 permitted to proceed with their work until they have submitted a 3 quality assurance manual describing their quality assurance program and 4 have received approval from PG&E. "
5 Based upon the above it is apparent that the H. P. Foley Company was required to 6 implement a Quality Assurance Program as required by 10 CFR 50, Appendix B.
7 No items of noncompliance or deviations 8 were identified." (Attachment 2 at 5-6.)
9 10 That the Foley Company and PGandE had functioning 11 construction QA/QC programs can not be disputed and is not 12 disputed by Mr. Tennyson:
13 "Q. I see. We've talked about several issues so far today. We've talked about ,
14 the red tag issue, we've talked about l inspection staff confiden -- compe-15 tence, and we've talked about the weld rod control issue that occurred in the 16 latter part of February and early March of '83. Were there any other instances 17 that you have knowledge of where quality requirements were not properly followed 18 within the area of jurisdction of H. P.
Foley Company at Diablo Canyon?
19 "A. [ Tennyson] None that I- could 20 specifically call out right now, but ,
they are all on file within the Pacific 21 Gas and Electric Company's audit group.
I mean, their QC and their QA performed 22 audits and did write procedural !
violations up against the Howard P.
23 Foley Company.
l 24 Q. Were there any of these insthnces .
which to your knowledge were not proper-25 ly followed up?
26 ///
1 l
l i
l j0
'D 1 A. Not to my knowledge." (Mar. Tr. at 68.)
2 3 Iten II.G of the Hubbard declaration (p. 24) 4 asserts that the H.,P. FoleyQA[QCProgramdidnotaddress 5 Class-II items and that this is contrary to the requirements 6 of GDC,-1,ito Appendix A of 10 CFR Part 50. Similarly, in 7 ent[merating " flaws" in the PGandE and Foley CQA Programs, l
L 8 Jo;nt Interveriors assert (J.
i I. Br. at 12-13).that one of 9 these " flaws" was the " failure to inspect non-safety grade 10 structures, systems and components important to safety."
l 11 $$oth of these asss.rtions cite statements by Richard E. Roam.
12 (Apr. Tr. at 53.)f; ,/ ,
13 Both as rtions are incorr'ect. '
They re incorrect l i 14 because tney are based on a misrepresentation;of the meaning
> ; I,, -
l
~
15 of " Design Class <.
i II" with respect to classiTication of
.- 16 structure <i, systerts and components at Diablo Canyon. '
In his
,-r 'r l - le ,
declarshion, Hubbard" prefaces his ' referen;ce sto Page 3.1-4 of
' ' 17 ,..-
18 the Diablo Can$onj FFAR Sy statinggthat "In the Diablo Canyon p
( *l- , /r 19 [ FSAR, PGindE defines those items that are important to - -
20 safety, tut not safety-related as follevsp' 21 / "Those items , imp'ortant , to' the reactor operation but'/ net essential to - :aafe 22 shutdown and iisblation of the.neactor or control of the -release of substantial
.23 amounts of radioactivityJare designated Class II." -
24 -
t O 25' l The ab'ove, quoted underlined introductory words are (Q
26 Hubbard's. They are not contained in the FSAR reference, -
., +
...g/.
^
r /, / ', -
1 nor are they to be found anywhere in the FSAR or in any 2 other Diablo Canyon licensing , documents. The referenced 3 FSAR definition is 4not a defirition of items important to 4 safety. It is, in' fact, just the opposite. The definition 5 of Design Class II is ahplicable onlyi toiitens which are not 6 important '. to - safety '. The definitions of Design Class I, II
( ,
and III s t ructures'.. systems, and components are summarized 7 ' '
s, 8 in Table 3.2-1 from the Diable' Canyon FSAR and it, along 9 with the full text o'f FSA.R Page 3.1-4 are attached hereto as 10 Exhibit 3'. ' These definitions make it, clear that any plant 11 feati:reE . important to safety are' classified ;as Design ,
q, 12 Class'I and are required to meet the requirements of GDC-1.
OJ 13 Design -Class II features are,. by definition, not 14 safety-related, ~ apd are not required to meet GDC-1
] requirements.m 15
! 16 , Given the fact that. Design Class II components are 17 ~not required to meet GDC-1 requirements and are not required 13 to , meet the requirements of Appendix B (See Table 3.2-1),
19
.Mr. Roam's statements on page 53 of the April 5 transcript
. 20 can be seen to support the adequacy of the Foley QA/QC
?21 Program. The program was applied only to Class I items 22 because only those items are safety-related.
23 Some of Mr. Hubbard's " misunderstanding" arises l '24 out of' his seemingly intentional misuse of the terms
/n 251 " safety-related" and "important to safety" . As pointed out M) .
in PGsndE's Response to Interrogatories 12 and 13, (Pages 30 26 1 ..
9 y x
- ,. , . - - - _ -,.--,_w- - -----,.-.-.,4
bO .
I and 31 of Pacific Gas and Electric Company's Answers to 2 Governor George Deukmejian's and Joint Intervenors' First 3 Set of Interrogatories) these terms are used interchangeably 4 in the Diablo Canyon FSAR and were always intended to have 5 the same meaning. The definition of Design Class I is 6 applicable to both terms. The definition of Design Class II 7 includes neither.
8 The term "important to safety" was used in the 9 Diablo Canyon FSAR and in GDC-1 many years before any 10 definition which attempted to distinguish the term Il "important to safety" from the term " safety-related". It is i 12 not an accident that the FSAR terminology is consistent with O The terms "important to safety" in both the Design 13 GDC-1.
14 Class I defin.i tion and in GDC-1 were intended to apply to l
15 the same Class I structures, systems and components. As Mr.
16 Hubbard very well knows, "important to safety" and 17 " safety-related" were synonymous terms until at least 18 November of 1981 when the so-called "Denton letter" was 19 issued in an attempt to distinguish the terms for future 20 use. PGandE finds it somewhat unsettling that Mr. Hubbard 21 would attempt to mislead this Board by stating that 22 "important to safety", as originally used in GDC-1 and the 23 Diablo Canyon FSAR, means something other than
! 24 " safety-related" or Class I.
l O 25 ///
l O 26 ///
l l
l l l
1 Nonconformance Documentation and Red Tag Removal 2 Movants would have this Board believe that a total 3 breakdown resulted in the " red tag" process. However, aside 4 from the isolated incident discussed below, the red tag 5 procedure was, and continues to be, assiduously followed.
6 As stated by Tennyson:
7 "And the question is: Did you follow the procedure that Mr. Moses asked you 8 to follow?
9 MR. TENNYSON: Yes, I think I did.
10 No, nc. I'm sorry.
11 Not the one Mr. Moses asked me to follow. I followed the procedure which 12 was established and is a QCP-3 reporting
{a) 13 of nonconforming conditions.
MR. KAUFMAN: So your department con-14 tinued to red tag everything that was nonconforming.
15 MR. TENNYSON: Yes." (Apr. Tr. at 36.)
16 f 17 A procedural violation was detected regarding " red 18 tags" that were prematurely removed in the fuel handling 19 building. The movants attempt to make much more of this 20 violation than is warranted. The NRC investigation revealed 21 that with the one exception, nonconformance reports and 22 their associated " red tags" were being properly controlled 23 and processed. The one exception, the removal of 24 approximately 10 of 15 tags after work had been inspected
, 25 and accepted on the 10 items but before final approval of 26 the entire nonconformance report, did not result in any sort
f 1 l of substantive problem and was an isolated case. (BME Aff.
2 at 13-14.) The NRC investigation revealed the following:
3 Concern: The concern was expressed or implied that, in general, nonconformance 4 reports and their associated " Red Hold Tags" were not being properly controlled 5 and processed.
6 NRC Findings: This concern was not sub-stantiated.
7 The NRC inspectors performed a documen-8 tation examination of all of H. P.
Foley's nonconformance reports, written 9 in February and March 1983, for the Fuel Handling Building modifications. From 10 these nonconformance reports, approximately ten uncompleted reports 11 were selected and the proper posting of the associated " Red Hold Tag" confirmed 12 by locating the actual tags in the field. The inspectors also compared the
% 13 rough drafts of all of the above mentioned nonconformance reports to the 14 final typed versions. This examination indicated that there were no significant 15 changes between the initial drafts and the final versions of the reports.
16 Subsequently, the inspectors I 17 examined the documentation and technical resolution of all of the above noted 18 nonconformance reports to determine if the resolutions appeared acceptable.
19 All resolutions were determined to be acceptable and technically adequate, 20 except for one report, as detailed below.
21 Nonconformance Report No. 8833R-54, 22 dated March 23, 1983 describes a situa-tion where Nondestructive Examination of 23 fillet welds for structural steel connections in the Unit No. 1 Fuel 24 Handling Building identified a number of weld discrepancies. The type of weld 25 discrepancies identified included O 26 cracks, linear indications, and undercut
Q kJ 1 and involved 16 structural steel connections. The inspector notes that 2 each connection contains over 60 welds.
The section of the NCR entitled " Dis-3 position including means to prevent recurrence" required the removal of the 4 weld discrepancies in accordance with Foley's weld repair procedures, and 5 contained the further amplification, "To change the rod issue period to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 6 to prevent moisture pickup and/or add portable rod ovens until the rainy 7 season ends." This disposition was approved and signed by the responsible 8 licensee personnel.
9 The apparent implications of this type of weld discrepancy did not appear 10 to be evaluated by the licensee or H. P.
Foley for generic consequences. Dis-11 cussions with Foley quality supervision and engineers indicated that they would 12 discuss this item with licensee con-struction and engineering personnel to Ad 13 determine whether the disposition was i
properly evaluated in accordance with 14 quality and regulatory requirements.
This item is considered unresolved pend-15 ing examination of the licensee's evaluation of this subject.
16 (50-275/83-13-03 and 50-323/83-10-03)"
(Attachment 2 at 10-11.)
17 18
" Concern: The specific concern was 19 expressed that near the end of 1982 approximately ten " Red Hold Tags" at-20 tached to nonconforming material in the Fuel Handling Building were removed by 21 the night shift Assistant Quality Con-trol Manager in violation of procedural 22 requirements.
23 NRC Findings: This concern was sub-stantiated.
i 24 l In addressing the specific concern that O 25 approximately ten " Red Hold Tags," had b 26 been Building removed in from violation the Fuel Handling of procedural i
O inspectors 1 requirements, the first attempted to locate and examine the sub-2 ject tags. Testimony by the former Quality Control Manager indicated that 3 the tags in question had last been seen in the H. P. Foley Quality Control 4 Manager's office.
5 On March 30, 1983, the NRC in-spectors conducted a search, of the 6 H. P. Foley Quality Control Manager's office. The subject tags were not lo-7 cated. Discussions with H. P. Foley personnel indicated that the subject 8 tags were probably destroyed after com-pletion and approval of the associated 9 nonconformance report. The H. P. Foley Quality Control Plocedure for Processing 10 and Control of Deviations and Non-conformances, QCP-3, does not require 11 the retention of " Red Hold Tags" as quality records.
12 O The interview with the new Assis-b 13 tant Quality Control Manager indicated that the " Red Hold Tags" in question l 14 dealt with nonconformances in the Unit 2 l
Fuel Handling Building where gouges had 15 been made on about 15 structural steel beams during removal of grounding pads l 16 (connections to the structural steel for All of electrical equipment grounding).
17 the nonconforming beams were documented on Nonconformance Report (NCR) No.
18 8802-802 and each beam was tagged with a
" Red Hold Tag" referencing NCR No.
19 8802-802. The repair of these gouges had proceeded to the point where much of 20 the work was completed, though a few l
beams still required repair. The work 21 on the already repaired beams had been accepted by Quality Control, but in l 22 accordance with procedural requirements, as contained in H. P. Foley Procedure 23 No. QCP-3, none of the " Red Hold Tags" could be removed until the repair work 24 on all of the beams was accomplished, accepted by Quality Control and the 25 appropriate approval signatures,obtained (Q
' j 26 from H. P. Foley and PGandE engineering.
l l _
A V
1 As indicated in the testimony of the former Quality Control Manager, 2 craft personnel were and are extremely hesitant to work near or around " Red 3 Hold Tags." Production supervision, on or about January 29, 1983, requested (of 4 Quality Control) that " Red Hold Tags",
attached to beams on which work had been 5 inspected and accepted, be removed so that craft personnel could proceed with 6 regularly scheduled work in the area.
The new Assistant Quality Control Man-7 ager (at the time the night shift Assistant Quality Control Manager), upon 8 reviewing the completed and accepted work, removed the " Red Hold Tags", for 9 those beams where the work had been inspected and accepted by Quality 10 Control. During the interview, the Assist. ant Quality Control Manager in-11 dicated that he did not, nor did he at the time of the interview, recognize 12 this action as a violation of Quality Control Procedure QCP-3. The individual
' 13 specifically stated that the removal of the " Red Hold Tags" (by him) was not 14 done as a result of threats or intimida-tion by production management. The 15 removal of " Red Hold Tags" prior to final approval of the entire nonconform-16 ance report appears to be a procedural violation of QCP-3. H. P. Foley Quality 17 Control Procedure for Processing and Control of Deviations and Nonconform-18 ances, QCP-3, Revision 5, states in paragraph 4.3.11 that, "When all of the 19 above steps (the steps delineating the review and approval cycle of the non-20 conformance report) have been completed the Nonconformance Report shall be 21 forwarded to Quality Engineering who shall coordinate removal of the " Red 22 Hold Tags" and file the report in the Quality Files." The failure to comply 23 with quality procedures for controlling and processing nonconformance reports is 24 considered an apparent violation of 10 l
CFR 50, Appendix B, Criterion V, "In-25 structions, Procedures or Drawings.
D (50-323/83-10/01)" (Attachment 2 at 26 3-5.)
A
'IV 1 Quality vs. Schedule 2 As with the vast majority of the allegations and 3 arguments arising out of the April 5 Tennyson / Roam 4 statement, the question of quality versus schedule deals 5 with the time frame from December 1982 to March 1983.
6 Movants offer several cites to the statement where indeed 7 Messrs. Tennyson and Roam complain of " pressure" being 8 brought to bear on them by their superiors and even by 9 PGandE. However, it is never stated whether the " pressure" 10 was to avoid the job of quality control, as movants would 11 have this Board believe, or, as other quotes from Messrs.
I s 12 Tennyson and Rcam indicate, " pressure" to do the job of 13 quality control in a better and/or a more expeditious 14 manner. For example, Mr. Tennyson, in his March statement
! 15 to the NRC, indicates that all " mistakes" were " identified 16 and corrected," with no " intent to not repair anything."
17 (Mar. Tr. at 28).
18 The NRC, during their investigation, likewise 19 found no evidence of excessive production pressure on QA/QC 20 personnel:
21 " Concern: The concern was expressed or implied that excessive production pres-22 sure, which allegedly manifested itself in the form of threats and intimidation 23 toward quality personnel, subsequently resulted in by-passing of established 24 quality control hold points and pro-cadures.
' NRC Findings: This concern was not 26 substantiated.
d i
i i
l o 1 A specific instance involving the i
violation of procedures for resolving a 2 nonconformance report was identified.
However, this item was not determined to 3 be the result of harassment or threats i by production management. This item is 4 discussed separately in paragraph 5b.
, [This was the " red tag" removal, dis-5 cussed supra.]
6 To establish. whether the concern of threats and intimidation toward quality 7 personnel had substance, interviews were conducted with several H. P. Foley per-8 sonnel including the Project Manager,the
! Acting Quality Control Manager, the i 9 Quality Assurance Manager, a number of Quality Control Supervisors, Inspectors,
These interviews centered on whether any l 11 of these individuals had knowledge of any threats or intimidation directed o 12 toward themselvcs or quality and craft personnel in order to enhance production ,
b 13 to the detriment of quality. While all personnel interviewed acknowledged a 14 certain amount of pressure to expedi-tiously complete assigned tasks, none i
15 expressed any knowledge of threats or i intimidation made either to themselves 16 or in their presence. None of the personnel interviewed expressed any 17 knowledge of directives from production management to by-pass quality control 18 hold points, deliberately violate pro-cedural requirements, and/or falsify 19 quality records." ( Attachment 2 at 5. )
20 Design Quality 21 Movants argue from a series of quotes from Messrs.
22 Tennyson and Roam that " mirror-image" drawings continue to 23 be a problem, that design changes are not being properly l 24 handled and the like. Again, the allegations and arguments 25 deal with the time frame of the past several months. Also 26 again, the NRC found the allegations to not result in any
/3 U
1 deviations or noncompliances even though a concern was 2 substantiated in part.
3 " Concern: The concern was expressed or implied that the installation and 4 routing of instrumentation tubing and electrical conduit and associated 5 supports were performed without design drawings.
6
' NRC Findings: The concern was substan-7 tiated in part, however, no safety concern was identified.
8 A review of the installation program 9 indicated that instrumentation tubing and electrical conduits were generally 10 field routed. This procedure requires that the craftsman route the tubing and 11 conduit per allowable pre-specified guidelines (slopes, curvature, joining 12 locations, etc. through the "best" route O available). This method was specified to accommodate obstructions (hangers, 13 re-bar and support installations, etc.) ,
14 that may exist in the field. A review of the programs utilized by the licensee 15 for installation of supports and routing of electrical conduit and instrumenta-16 tion tubing is given below.
17 (1) Electrical Conduit Supports: From the start of constuction, supports 18 have been designed by engineering at PG&E's General Office and 19 installed per those designs. These designs have been formalized in 20 controlled drawings Nos. 050029 and 050030. These drawings initially 21 were issued on January 20, 1969 and l
June 7, 1971, respectively. These 22 drawings provide notes, symbols and typical details of Raceway and Wire 23 Supports, and Class IE Electrical Raceway Supports, respectively.
24 Therefore, electrical conduit sup-ports appear to have been control-25 led and installed by the use of the pd pre-established design details 26 described above.
O 1 (2) Instrumentation Tubing Supports:
At the start of construction, 2 installation occurred without a formalized set of controlled 3 drawings, however, an engineering review of each as-built installa-4 tion was performed by licensee engineering personnel after instal-5 lation. On April 3, 1974, the licensee adopted a controlled 6 drawing No. 049238 which contained acceptable instrumentation supports 7 and design methods. Also at this time,the licensee required as-built 8 drawings of all instrumentation tubing supports; and for those 9 supports that were not detailed in controlled drawing No. 049238 an 10 engineering analysis was performed.
After April 3, 1974, instrumenta-l 11 tion tubing supports were built and inspected for compliance with the 12 drawing of acceptable supports and design methods.
There fore, the concern was substantiated 14 in part in that no unique design drawing exists for each electrical conduit and 15 instrumentation tubing run or support.
However, this condition is acceptable 16 since other compensating control mea-sures were and are implemented.
17 Additionally, the conduct of inspections 18 per the Systems Interaction Program (SIP) provides assurance that failures 19 in a non-safety related system will not l adversely impact on adjacent safety l 20 related systems. This includes instru-l mentation tubing and electrical conduit, 21 so that additional assurance of the acceptability of actual field routing is 22 provided by the SIP Program.
23 No items of noncompliance or deviations were identified." (Attachment 2 at 24 11-12.)
l 25 ***
26 ///
1 " Concern: The concern was expressed or l
implied that the Quick Fix Design Change 2 (QFDC) procedure and Engineering Dis-position Request (EDR) program are used 3 to bypass quality control functions.
4 NRC Findings: This concern was not i substantiated.
5 A review of the QFDC and EDR programs
! 6 determined that both of these programs are used for in-process design changes
', 7 or clarifications. These programs are l designed to expedite work on modifica-8 tions in order that when a problem was encountered, or there was a question on 9 the engineering interpretation of a design, the QFDC or EDR programs, 10 respectively, could be used to obtain a response from engineering before quality 11 control would be directed to perform their inspection.
12 1 The QFDC procedure draws its authority 4
l 13 from PG&E's Procedure for Civil
! Structural Design Modification (No.
14 CE-DC-5). Section 3.6 of this procedure
! states that, " General Construction may 15 as-built in accordance with their
- guidelines or obtain approval from the 16 Onsite Project Engineering Group (OPEG) or Home Office." With this authority,
! 17 PG&E General Construction has required H. P. Foley to establish a procedure for 18 the QFDC.
19 H. P. Foley Procedure QCP-17, Appendix j F, prescribes the requirements for the i 20 control of QFDC's. This procedure i
describes how modifications of approved i 21 issued drawings are to be initiated.
The intent of this procedure is to 22 provide a system for controlling and approving design changes in a timely
- 23 manner. This system may be used to
! address such things as errors, omissions 24 on drawings, interferences, simplifica-i tion of work, in-process work correction 25 and drawing interpretation. The system ;
i assures than any design changes, gener- l 26 ated in accordance with the requirements i
i 1
G IQ 1 and limitations of this procedure, are i properly addressed.
2 Further, this procedure establishes that 3 H. P. Foley Quality Control is to provide inspection and documentation of 4 work performed in accordance with this procedure and other applicable pro-5 cedures. Therefore, the QFDC explicitly requires quality control inspection.
6 H. P. Foley Procedure (QCP-1) prescribes
- 7 methods for the use of Engineering Disposition Requests (EDR), which are 8 H. P. Foley prepared documents that request engineering interpretation of 9 design and are sent to PG&E for evalua-tion and resolution. The responsible 10 Resident Engineer for PG&E then prepares a disposition and transmits the EDR back l 11 to H. P. Foley. H. P. Foley uses the l disposition to resolve the situation, 12 and the work proceeds with the EDR attached to the work package for clari-O- 13 fication.
! 14 Therefore, the QFDC and the EDR program are controlled and do not by-pass 15 quality control functions.
16 No items of noncompliance or deviations were identified." (Attachment 2 at 17 12-13.)
l ***
18 19 " Concern: The concern was expressed or implied that the " mirror image" concept 20 used in the construction of Unit No.1 and Unit No. 2 was confusing and 21 resulted in excessive craft errors.
22 NRC Findings: This concern was not substantiated. However, it should be 23 recognized that the " mirror image" concern did contribute to the design 24 problem that resulted in the suspension of the Unit No. 1 fuel load / low power n 25 test license in November 1981. This V 26 subject is being addressed in a compre-hensive program for the reverification
O 1 of the plant design and is outside the scope of this special inspection.
2 In addressing the concern that the 3 " mirror image" concept caused confusion and craft errors during the installation 4 of equipment and systems in the field, the inspectors interviewed H. P. Foley 5 Company production and quality ccntrol personnel to determine their impres.sions 6 of this concern. None of the individu-als interviewed indicated that ?.his 7 concern was valid.
8 No items of noncompliance or deviations were identified." (Attachment 2 at 19.)
9 10 Inspector Harassment 11 Movants argue that QC inspector harassment (again 12 within the past several months) is a further indication of a l i
! 13 faulty CQA program. It is implied by movants that the 14 incident of harassment referred to by Mr. Roam ( Apr. Tr. at
- 15 70) revolved around the inspector's work, i. e_., that he was j 16 harassed as a result of findings he made as a QC inspector.
l 17 In fact, the specific harassment, " patting him and cal 1[ing]
18 him ' fat boy' and threatening to kiss him on the cheek and 19 things of that nature," while certainly not acceptable was 20 not a result of the inspector's work. (BME Aff. at 14.)
21 Contrary to the allegation of Mr. Roam that ". . . I, in 22 turn, took the situation to Mr. Moses. Moses, as far as I 23 know, did absolutely nothing about it", the ironworker who 24 harassed the inspector was terminated for the offense.
25 (g. )
26 ///
O 1 As noted supra (at p. 32, et s_eg.), the NRC found 2 no evidence of any threats or intimidation directed toward 3 quality or craft personnel to enhance production to the 4 detriment of quality.
5 Material Acceptance
! 6 Movants correctly state that there was an i 7 " improper acceptance of nonconforming materials" (J. I. Br.
8 at 13) but fail to deal with the subject further. The 9 Hubbard declaration drastically misconstrues the i
10 Tennyson / Roam statement as respects pre-1974 inspections by 1
11 the Foley Company. (Hub. Dec. at 11-12.) What Hubbard 12 ignores is the scope of the work Foley was involved in 13 during the pre-1974 time frame and differences in 14 nomenclature between nonconformance reports and discrepancy 15 reports. The NRC investigation correctly reports that prior 16 to 1974 the Foley Company had no procedures for weld rod 17 control and the like for the simple reason that they did not 18 do any welding. When they later undertook that task, 19 welding control and weld rod control were specified. Again, 20 the NRC found the concern not to be substantiated:
21 " Concern: The concern was expressed or implied that prior to 1974, there was no 22 formal Quality Assurance Program, no nonconformance reports (NCRs) written, 1 23 and a weakness existed in Quality Con-trol functions (no inspection of tool 24 calibration, electrical raceways, weld rod control, welding procedure and mate-25 rial receipt).
26 ///
i t
1 NRC Findings: This concern was not sub-stantiated.
2 The inspector examined the quality 3 Programs for H. P. Foley prior to 1974.
The inspector's examination determined 4 that, for each contract awarded to H. P.
Foley by PG&E, there existed a Quality 5 Assurance Manual and implementing Quali-ty Control procedures. A description of 6 the various H. P. Foley quality programs follows:
7 The first contract specification awarded %.
P 8 H. P. Foley was specification Number 8807. This basic electrical contract 9 specification was appcoved by PG&E on September 4, 1970. The quality program 10 for this specification addressed:
11 1) Receipt, storage, haridling, and inspection of electrical equipment, 12 conduit, and wire.
- l. (( Installation of electrical equip-13 2) ment, conduit, cable trays, wire 14 and grounding. .
15 3) Document control and drawing con-trol 16
! 4) Control of test instrumentation i
17 equipment and tools 18 5) Quality Assurance Organization and qualification of personnel
- 6) Maintenance of installed equipment 20
- 7) Discrepancy reports and reject tags 21 (predecesscr to NCR and hold tags) 22 Welding or weld rod control was not ad-f dressed in this procedure until January 23 1974. The reason that no welding or weld rod control procedures existed, 24 during this period, was that H. P. Foley was not required by contract (Contract
, 25 No. 8807) to perform welding. When s H. P. Foley was awarded cleanup Contract 26 Specification Number 8771 (in January
O l 1 1974), welding and weld rod control re-quirements were included in both Con-2 tract No. 8807 and Contract No. 8771.
3 Prior to 1974, H. P. Foley had one addi-tional contract with PG&E (specification 4 No. 8802). This contract was for small electrical components, raceway, and 5 instrumentation installation and was approved by PG&E on August 8, 1972.
6 This specification included a Quality Assurance Manual and implementing 7 quality control procedures addressing:
8 1) Receipt, handling, storage, in-i stallation and maintenance of elec-9 trical equipment, cable trays and conduits 10
- 2) Wire pulling, testing and termina-11 tion ,
C\D 13 trol
- 4) Test instruments and control 14
- 5) Calibration of test instruments.
15 No welding or weld control was required 16 by this specification. Additionally, the inspector noted that a Discrepancy 17 Report process was in effect at the time and served the same function as the cur-
- 38 rent NRC process. Therefore, the Quali-l ty Assurance Manual and Quality Control l
19 procedures did include provisions con-trary to each of the expressed or im-20 plied concerns.
21 No items of noncompliance or deviations l were identified." (Attachment 2 at 22 17-18.)
23 As to the instance where nonconforming materials were 24 improperly accepted the following should be noted:
25 (i) this matter was thoroughly investigated by the NRC 26 in 1981-82,
t
. O corrective action was taken by Foley and PGandE
< 1 (ii) 2 and then verified by the NRC in 1982, 3 (iii) the matter did not result in any material that was 4 in fact physically nonconforming being used at 5 Diablo Canyon. (NRC Audit Rpt. 50-275/82-26 and 6 50-323/82-13.)
7 The " revelation" by Messrs. Tennyson and Roam of this 8 concern may have been a surprise to the deputy attorneys 9 general and Joint Intervenors but it had been a matter of 10 public record since early 1982 and remedied before it was 11 brought out in the Tennyson / Roam statement, a fact which Messrs. Tennyson and Roam inexplicably failed to point out 12 13 to the deputy attorneys general. The NRC investigation of 14 this concern shows the following:
15 " Concern: The concern was expressed or implied that material from Bostrom-16 Bergen Company was received without the l necessary documentation.
i 17 l NRC Findings: The concern was substan-18 tiated, however this item was the subject of previous NRC enforcement 19 action (
Reference:
NRC Inspection Report No. 50-323/82-09) and corrective 20 action has been verified by the NRC
(
Reference:
NRC Inspection Report No.
21 80-323/82-13).
22 On December 14, 1981 an allegation concerning acceptance of Bostrom-Bergen 23 supplied material by the H. P. Foley Company, without the proper documenta-24 tion was received by the NRC. Subse-quent investigation of this allegation i 25 (see NRC Inspection Reports Nos.
50-323/82-06, 82-08 and 82-09) resulted f( 26 in the issuance of an item of'noncompli-l t
O 1 ance on June 14, 1982, documentating the failure of H. P. Foley to follow quality 2 procedures in the processing of noncon-forming material. In response to the 3 item of noncompliance, the licensee directed the contractor to perform a
- 4 100% audit of all Class I purchase orders dating back to 1978, to revise 5 the contractor's procedures to ensure that proper controls exist for control-6 ling of nonconforming material until receipt of proper documentation, and to 7 conduct training sessions for personnel in regard to these procedure changes.
8 As documented in NRC Inspection Report No. 50-323/82-13, the NRC inspector 9 verified implementation of the licens-ee's specified corrective actions and 10 concluded that the licensee's actions were proper and satisfactory.
11 l
No additional items of noncompliance or l 12 deviations were identified." (Attach-ment 2 at 15-16.)
14 Overtime Work 15 Movants argue that overtime work by quality 16 inspectors is indicative of failures in CQA. While such an i
17 argument is speculative, it would certainly be logical to 18 assume that if workers were required to work to the point of 19 not being able to function properly, then the quality of 20 their work would suffer. This allegation was not made. Ten 21 hour workdays for a six day work week do not equal an 22 inability to do one's job. In its investigation the NRC was 23 once again unable to substantiate the concern.
24 " Concern: The concern was expressed or 6 implied that excessive work hours were l 25 adversely affecting the quality control B inspection effort.
26 l
l i l
l b
1 NRC Findings: This concern was not substantiated.
2 An examination of tabulated work-hours 3 for H. P. Foley Quality Control Inspectors and Supervisors, between 4 December 7, 1982 and March 8, 1983, indicated that 90% of all Quality 5 Control Inspectors and Supervisors worked mo7e than 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> a week during 6 this period, with three inspectors working 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> a week or more. The 7 relationship between excessive work-hours for Quality Control personnel and 8 the effect on the quality of their inspection effort cannot be precisely 9 established, though the NRC has previ-ously identified problems with H. P.
10 Foley's welding activities in the Fuel Handling Building (
Reference:
NRC 11 Inspection Report No. 50-275/83-08 and paragraph 5p of this report). Excessive 12 work hours are clearly undesirable, and
( discussions with licensee representa-13 tives indicated that actions have been taken to reduce the amount of overtime.
14 Licensee and contractor actions in this area will be assessed in the NRC 15 followup to the notice of violation issued in NRC Inspection Report No.
16 50-275/83-08).
17 No items of noncompliance or deviations were identified." (Attachment 2 at 14.)
18 19 ///
20 ///
21 ///
+
22 23 24 2s 0 26
l 1
J t
1 C. The Independent Design Verification Program's Interim Technical Reports Nos.
2 36 And 38 Provide Further Assurance That Construction Quality Assurance At Diablo
! 3 Canyon Was Adequate And Do Not Provide Significant New Evidence Which Would #
4 Lead To A Different Result.
i 5 IDVP's CQA Evaluation 6 PGandE voluntarily committed to perform a 7 construction quality assurance review for Diablo Canyon 1
! 8 Unit 1. This CQA program was proposed by PGandE to confirm 9 the adequacy of the construction of Diablo Canyon, and to
! 10 demonstrate PGandE management's ongoing attention to quality 11 assurance. During the month of September, 1982, Teledyne ,
12 Engineering Services (TES) and Stone and Webster Engineering 13 Corporation (SWEC) were chosen to manage and conduct the 14 independent CQA evaluation as an adjunct to the Independent 15 Design Verification Program (IDVP) Phase II Program, in 16 accordance with applicable portions of the Phase II Program 17 Management Plan. (Transcript of NRC & PGandE meeting, 18 January 13, 1983, at 96.)
19 Mr. Hubbard would have had the IDVP's scope 20 restricted to a statistically random sample of construction !
21 activities (Hub. Dec. at 30) rather than focus on systems, 22 components, and structures most important to protection of 23 the public's health, safety and welfare. Rather than limit 24 the CQA evaluation to a random sample, it was thought that 25 it would be more meaningful to evaluate the adequacy of two 26 of the more important, if not the most important, vital i
I
i O
1 safety-related systems. The scope of the review was 2 specifically chosen to include two of the barriers that 3 prevent radioactivity from reaching the environment. These 4 barriers, which form part of the defense-in-depth concept, i 5 are the primary coolant loop and the containment structure.
6 The construction contractors that installed these barriers 7 were Wismer & Becker Company (W&B) for the primary coolant 8 loop, and G. F. Atkinson Company (GFA) for the containment 9 structure. The review of their quality programs and the 10 work they performed formed the scope of the IDVP CQA 11 evaluation. (Ibid at 97.)
12 The on-site SWEC review team 6/ developed proce-13 dures and selected some 250 attributes for verification.
14 15 6/ The independent onsite SWEC review team consisted of a j
total of 10 personnel, including an onsite team leader.
16 All assigned personnel were qualified Level II or Level III inspection, test, or examination personnel or lead 17 (Level III) auditors in accordance with applicable ANSI or AWS standards and corresponding Regulatory Guides.
18 Moreover, the team has a combined experience of over 19 110 years in the nuclear industry. The team members were Senior Inspectors, Inspection Supervisors, QC 20 Engineers, Senior QA Engineers, Assistant Managers, or Consultants. The average creditable experience in 21 Engineering, Quality Assurance, or Project Management was almost 17 years for the assembled team; the major-22 ity of team members had over 10 years of experience.
23 The team was carefully assembled to provide the neces-sary qualifications and experience in the significant 24 task areas. For example, welding records were reviewed p by an AWS certified team member, NDT records by a team (V 25 member qualified to SNT-TC-1A, Level III, civil records by a PE who is also an ASME, Level III. In every case personnel were assigned duties based on their specific 1
26 discipline activity and area of expertise. (Appendix D of Attachment 3 hereto.)
1 The verification process looked for documentary evidence of 2 adherence to approved procedures and specifications, as well 3 as physical evidence of conformance with design intent..
4 (Ibid at p. 96.)
5 Fo] lowing the review, the Findings Review 6 Committee 7/ (FRC) made a recommendation to TES for 7 classification of the potential findings. Upon review and 8 determination of significance, TES issued the Potential 9 Findings Reports (PFR) in 29 Open Item Reports (OIRs) and 10 PGandE commented on these OIRs. These potential findings 11 were subsequently classified to one finding, 23 observations and 5 invalid concerns. The IDVP's finding and observations Q 12 N 13 are documented in ITR No. 36, Revision 1, and ITR No. 38, 14 Revision 2, which are Attachments 3 and 4, respectively, to 15 this response. Those revised ITRs were revised by the IDVP i
i 16 to allay the NRC staff's concerns mentioned in the Novak to 17 Cooper letter of May 2, 1983.
le ///
19 ///
20 ///
21 22 7/ The Finding Review Committee consisted of five members 23 whose combined experience includes 110 years in con-struction of which over 85 years was in the nuclear and 24 quality assurance related fields. Their expertise includes management for construction of various nuclear g 25 facilities, engineering design and testing, and con-struction quality assurance / quality control. (Appen-26 dix F of Attachment 3 hereto.)
gD 1 G. F. Atkinson Company Evaluation 2 As stated in ITR No. 36, Revision 1, SWEC was en-3 gaged by TES to perform evaluations and verifications of the 4 quality related activities of GFA which had performed civil /
5 structural work in the containment building at the Diablo 6 Canyon Nuclear Power Plant Unit 1. (Attachment 3 at 1-1.)
7 SWEC performed the evaluation and verification in 8 accordance with the IDVP Program Plan, Revision 1, " Adjunct 9 Program for Evaluation of Construction Quality Assurance,"
10 dated October 1, 1982. This program plan is attached as 11 Appendix C to Attachment 3.
12 The IDVP report concentrates on that portion of 13 the civil / structural work performed by GFA and its major 14 subcontractors on the Unit 1 containment. Major 15 subcontractors to GFA and their primary functions included:
16 . Pacific States Steel - supplying and erecting 17 reinforcing steel 18 . Pittsburgh Testing Laboratory - reinforcing steel 19 testing and inspection 20 . Pittsburgh Des Moines - liner erection 21 . Bostrom-Bergen - supplying embedded metal 22 Subcontractors functioned under their own PGandE 23 approved quality assurance programs and GFA performed 24 Periodic audits of their performance. Concrete work for the 25 containment structure was initiated in September 1969 and iO 26 was essentially completed in 1973. (Ibid at 1-1 and 1-2. )
jQ (Q
1 The FRC conducted a site visit on November 16 and 2 17, 1982. During this site inspection, each PFR was physi-3 cally/ visually reviewed by one or more members of the FRC.
4 Each PFR was evaluated according to the review criteria 5 listed in Attachment 3.8 of Appendix E of ITR 36, 6 Revision 1. (Ibid at 1-3 and 1-4.) The FRC considered all 7 information supplied by their Site Team, PGandE and its 8 subcontractors, as well as consulting with the SWEC 9 Technical Division for technical evaluation of data and 10 information. The FRC's review included a full discussion of 11 the following considerations as a minimum:
12 . Is the observation programmatic in nature or is it 13 hardware-related?
l 14 . Would it have an impact on plant adequacy?
15 . Is it an individual failure to follow procedures?
16 . Does it appear to identify the symptom of a 17 problem of generic nature?
18 . Were procedures inadequate to prevent the 19 observation?
20 . Are personnel aware of requirements?
21 . Has a Code or Standard been violated?
22 . What may reasonably be considered the effect on 23 the plant if left undetected?
24 . Is there a potential for end product deviations or 25 deficiencies?
26 ///
C 1 1 . Were there subsequent tests or inspections to 2 confirm the adequacy of the item?
3 . Are the possible adverse effects of the potential e finding likely to affect the operability or safety 5 of the plant? (Ibid at B-i and B-ii.)
6 Evaluaticn of GFA's construction quality assurance 7 program consisted of a review of contractor's quality 8 programs to determine if adequate controls and practices 9 were evident to assure the quality of construction and the 10 incorporation of essential design features into the 11 completed plant, and to determine if controls were j
12 consistent with applicable regulatory requirements at the i
L 13 time the work was performed. (Ibid at 2-1.)
14 Based on the checklist attached as Appendix G1 in 15 ITR 36, eighteen-hundred documents were reviewed against the 16 appropriate attributes. PGandE was involved in the quality 17 program as evidenced by its approval of contractor and 18 subcontractor Quality Assurance Programs, approvals of NCRs, !
19 audits of subcontractors, and corrective action followup.
20 (Ibid at 4-1.)
21 The documentation reviewed provides evidence that 22 an effective quality control program existed and was 23 enforced to ensure that work was performed in accordance 24 with the PGandE specification, GFA's Quality Assurance 25 Program, and the Quality Assurance Programs of GFA's 26 subcontractors. Records were logically filed, easily
0 ~
1 retrievable, and particularly detailed in their coverage.
'2 Deficiencies identified by the contractor during the program 3 of work were documented on NCRs and corrective actions were 4 effectively implemented. PGandE played an active role in 5 the resolution of nonconformances and performed periodic 6 audits of major subcontractors to assure program adherence.
7 (Ibid at 6-1.)
8 Verification of GFA's physical installation 9 consisted of an evaluation to detarmine if physical 10 installation of selected components of safety systems and 11 structures conformed to the requirements of design ' drawings 12 and specifications and whether required inspections vere l
13 performed. Based on the checklist attributes, 323 items
'14 were visually inspected. (Ibid at 2-1 and 4-1.)
15 The physical verification indicated that GFA , and i
16 its subcontractors performed work as specified and in 17 accordance with their quality programs. Other than the.
18 items identified in the Open Item Reports (OIRs) discussed 19 in Section 5 of ITR 36, "EOI Reports Issued," all work which 20 was accessible for inspection was performed in accordance 21 with the approved drawings and PGandE Specification 8831R.
22 (Ibid at 6-1.)
23 It is the conclusion of the FRC that in 24 containment, the civil / structural work performed was 25 satisfactory. The FRC found that adequate controls and 26 practices were in place to assure the quality of 1 -- --
^ '~
s_ '
), ,
(,
t'
,r <
l i
\
\
I
('V
/
l 1 construction. Further, the as-constructed physical 2 installation meets the intent of the requirements of design 3 drawings and specifications, and the required inspections li '
4 - welte performed and appropriately l doc 0mented. The FRC
'S considers th5' number and significance-of the observations to 6 be as expected for the extensfie revie,w of.both hardware and 7 documentation which was pe/Ecrmed. . The' ' installation was
/
8 considered t'o be acceptable and th,e FRC concluded that no r - -
9 ' additional verification w,as. recommended. (Ibid at 7-1. )
'i0 The fil s issued by SWEC were reviewed thoroughly 11 by TES and specific recommendations were made to the IDVP 12 Program Manager delineating appropriate resolution. (Ibid 13 at H-1.1 A s ,3 result of the verification of the selected l
l ,14 samples and the ast.essment of the impact of SWEC's findings, 1- 15 TES, as' Program M411ager, was also of the opinion that no 16 additional verification was required. (Ibid at H-1.)
17 Wismer & Becker Company Evaluation i 18 As stated in 'ITR No. 38, Revision 2, SWEC was 19 engaged by TES to, perform evaluations and verifications of 20 the quality related activities of W&B who performed l
21 installation. of NSSS piping for Unit 1 of the Diablo Canyon 22 Nuclear Power Plant. (Attachment 4 at 1-1.)
"23 SWEC has performed the evaluation and verification 24 in accordance with the IDVP Program Plan, Revision 1, 1
25 " Adjunct Program for Evaluation of Construction Quality l
(0 26 ///
--,.y. . - - -
O h _
Y '
1 Assurance," dated October 1, 1982, issued by TES as the IDVP o '
2 Frogram Managar. (,Id.)
3 The IDVP report concentrates on the work performed 4 by.W&B which consisted primarily of (1) final setting of the 5 major NSSS components (reactor vessel, steam generators, 6 etc.), and' (2) ' installation of the reactor coolant piping, 7 pressurizer surge line piping, bottom mounted 8 instrumentation '(BMI ) tubing, piping and tubing supports, 9 and reactor vessel flange seal leak detection tubing in 10 Unit 1. (Id.)
s Il The evaluation of W&B's construction quality 12 assurance program was structured to assess whether the
~ 13 cons'truction of Diablo Canyon was' performed in accordance 14 with quality requirements appropriate for the time of plant i
15 construction. (Ibid at 1-1 and 1-2.) The same 16 considerations shown supra (at p. 49) for the GFA evaluation 17 were used for the W&B evaluation. The evaluation, similar 18 to the GFA evaluation,- was conducted using a prepared ir 19 checklist consisting of 82 attributes that were derived from 20 the governing requirements. (Ibid at 3-1.)
21 Records obtained from the permanent plant file 22 were reviewed for cbjective evidence that requirements were 23 met in a satisfactory manner. The type of records reviewed 24 included ASME III Certificates of Authorization, Certified 25 Material Test Reports (CMTRs), Code Data Reports, Operation 26 Process Sheet Travelers (installation and inspection
l l
C 1 documentation), drawings, welding procedures, welder 2 qualification records, weld data sheets, welding electrode 3 control records, nondestructive examination (NDE) 4 Procedures, personnel qualifications and reports, 5 hydrostatic test procedures reports, audit reports, and 6 nonconformance reports (NCRs). (Ibid at 3-1.)
7 It was found that W&B was in compliance with 8 requirements for 65 of 80 attributes that were evaluated.
9 In accordance with specification requirements, the 10 contractor's Quality Assurance Program had been properly 11 submitted to and approved by PGandE. In addition, the 12 contractor was a holder of the ASME, Section III, (b' 13 Certification of Authorization for installation of nuclear 14 piping. The required Code Data Reports were properly signed 15 and certified by the Authorized Nuclear Inspector ( ANI).
16 Travelers, specifications, drawings, and procedures were 17 approved by PGandE prior to work being performed; the 18 travelers, which included inspection and test requirements, 19 were completed as work was performed including the signoff 20 at designated hold points by the contractor's inspectors and 21 the ANI. (Ibid. at 4-1.)
22 Further examples of activities which were found to 23 be in compliance with the source documents and associated 24 codes and standards are as follows:
25 . Installation operations (setting, shimming, 26 alignment, etc.) of NSSS major components
1 . Cleanliness and cleaning and flushing operations 2 in accordance with procedures approved by PGandE 3 . Qualification of welding procedures and approval
, 4 by PGandE and the ANI 5 . Selection of proper welding process (GTAW, SMAW) 6 . Control of welding electrodes 7 . Control of interpass temperatures l 8 . Repair of reported weld defects in accordance with 9 procedures approved by PGandE i
10 . Approval of NDE procedures and NDE personnel 11 qualifications by PGandE and the ANI 12 . Performance of required NDE 1
l 1 13 . Performance of audits It . Control of reported nonconformances, including the 15 approval of dispositions by PGandE (Ibid at 4-1 16 to 4-2.)
17 A total of 3,528 documents were reviewed. As a 18 result of the review, 16 Open Item Reports were issued to 19 document findings which required resolution. Most of these l
l 20 items can be characterized as omissions or as an inspection 21 activity which had to be evaluated to determine its impact 22 on the physical installation. (Ibid at 4-2.)
23 The documentation reviewed provides evidence that 24 an effective quality control program existed and was 25 enforced to assure that work was performed in accordance 26 with the PGandE specification and W&B's Quality Assurance
1 Program. Records were logically filed, easily retrievable, 2 and detailed in their coverage. Deficiencies identified by 3 the contractor during the program of work were documented on 4 NCRs and corrective actions were effectively implemented.
5 PGandE played an active role in the resolution of 6 nonconformances and performed periodic audits of 7 subcontractors to assure program adherence. (Ibid at 6-1.)
8 To verify the physical installation of W&B's work, 9 checklists were prepared based on design drawings, 10 specification requirements, reported as-built conditions, 11 and other appropriate design data (i.e., flow diagrams) for p 12 conducting the physical verification of construction 13 practices of the following systems:
1 14 . Reactor coolant piping 15 . Pressurizer surge line piping 16 . Bottom mounted instrumentation tubing 17 . Reactor vessel leak detection line 18 . Pipe and tubing supports for the four items above 19 Inspections were performed utilizing prepared checklists 20 consisting of 53 preselected attributes extracted from 21 specifications, drawings, and quality assurance / quality 22 control procedures. (Ibid at 3-2.)
23 All accessible welds in the systems described 24 above were visually examined to verify that fabrication, 25 examination, and documentation were performed to approved 26 procedures. All insulation was removed for the inspection.
)
l l
f3 (V
1 The entire reactor coolant piping system was examined by 2 individual spool and welds. d
(_I_d.)
3 Piping was verified against PGandE drawings and 4 W&B fabrication records. (Ibid at 3-3.) Welding was 5 verified utilizing W&B weld procedures (approved by PGandE),
6 W&B fabrication records, weld qualification records, and 7 weld issue records. (Id.)
8 An inspection of internal surfaces of reactor 9 coolant piping was one attribute on the checklist. Due to 10 clean condition restrictions in the reactor cavity area and 11 the vessel being partly flooded, it was only possible to t / 12 perform internal inspection of the hot and cold legs of
('
(Ibid at 3-3 and 3-4.)
13 Loop 3.
14 BMI tubing records consisted of two packages which 15 contained the documentation of all 350 welds. These records 16 were examined for evidence of correct documentation of:
17 . Correct weld identification 18 . Assignment of qualified welder 19 . Correct preheat 20 . Correct electrical characteristics 21 . Visual in :pections 22 . NDE
! 23 . Repair data (Ibid at 3-4.)
24 Steam generator snubbers were examined to 25 determine if location and orientation agreed with PGandE 26 drawings. (Ibid at 3-5.) Visual inspections were performed (fh G
1 using PGandE drawings to verify that components (i.e.,
2 reactor vessel, steam generators, pressurizer, etc.) were 3 correctly identified and properly oriented. (Ibid at 3-6.)
4 In conjunction with the physical verification, 5 supporting documentation (i.e. , welder qualification, weld 6 procedure approvals, NDE qualifications, and other 7 inspection reports) was reviewed for compliance to 8 specification and program requirements for the time of 9 construction. (Ibid at p. 3-6.)
10 It was found that U&B was in compliance with 11 program requirements for the vast majority of the attributes 12 that were verified. The configuration, cleanliness, surface 13 finish of welds, and overall workmanship were in compliance 14 with drawings and specifications with some exceptions noted 15 in the report. Of 2,298 items inspected, 9 Open Item 16 Reports were issued. The items identified primarily
! 17 demonstrate either a conflict between a drawing requirement 18 and the installation or apparent field changes that may not 19 have been properly documented. (Ibid at 4-3.)
20 The physical verification indicated that W&B 21 performed work as specified and in accordance with their 22 programs. Other than the items identified in the OIRs 23 discussed in Section 5, "EOI Reports Issued," all work which 24 was accessible for inspection was performed in accordance 1
25 with the approved drawings and PGandE Specification 8752.
(0' 26 (Ibid at 6-1.)
I l
1 It was the conclusion of the FRC that the work 2 performed on the reactor coolant system of Unit 1 at Diablo 3 Canyon was satisfactory. The FRC found that adequate 4 controls and practices were in place to assure the quality 5 of construction. Further, the as-constructed physical 6 installation meets the intent of the requirements of design 7 drawings and specifications, and the required inspections 8 were performed and appropriately documented. The FRC 9 considers the number and significance of the observations to 10 be as expected for the extensive review of both hardware and 11 documentation which was performed. The installation was q 12 considered to be acceptable by the FRC and no additional l 13 verification was recommended. (Ibid at 7-1.)
14 The files issued by SWEC were reviewed thoroughly l
15 by TES and specific recommendations were made to the IDVP 16 Program Manager delineating appropriate resolution. (Ibid I 17 at H-1.)
18 As a result of the verification of the selected 19 samples, and the assessment of the impact of SWEC's 20 findings, TES, as Program Manager, was of the opinion that 21 no additional verification was required. (Ibid at H-1.)
l 22 IDVP CQA And The Hubbard Declaration 23 The Hubbard declaration concerning alleged 24 " breakdowns" in construction quality assurance at Diablo 25 Canyon contains a multitude of allegations concerning the 26 findings of the IDVP CQA review. There is an overwhelming
('
1 body of objective evidence that Hubbard's allegations are 2 wholly unfounded and/or misconstrue the intent of ,
3 Appendix B. Mr. Hubbard alleges that the 23 Class C errors 4 and 1 Class A error identified by the IDVP in ITR Nos. 36 5 and 38 are evidence of numerous noncompliances that are 6 directly contrary to the QA/QC requirements of Appendix B.
7 (Hub. Dec. at 29.)
8 This allegation is contrary to Dr. Cooper's 9 statement to the NRC staff:
10 ... when I reread and others reread that last paragraph that you are 11 referring to in our ITRs where it said it met the specification in a few
,m 12 regards it clearly did not to the letter
(.
13 of the law meet the specification in the sense of meeting a regulation perhaps, but it clearly ended up with an 14 equivalent end product for the service requirement." (Attachment 5 at 30.)
15 16 In addition, Mr. Lundin stated:
17 "To us it was apparent that all the re-quirements of the procedures may not 18 have been followed in that case. I cannot identify the specific violations, 19 but that is a possibility that there were procedural failures, as I mentioned 20 earlier, that the program did not work l
l one hundred percent of the time, but in l 21 fact it worked acceptably as one would expect a program to work." (Attachment 22 5 at 61.)
l 23 Mr. Lundin continues by adding:
l 1
24 "Since we looked at all of their proce-dure compliance as far as it related to 25 whether the paper was there and the job i
(' got done, but since we looked at all of 26 it and felt that this was a failure in
(
1 an area which would not necessarily mean that the Wismer-Becker people didn't 2 follow Procedures. It was, on the con-trary, apparent that they normally did."
3 (Attachment 5 at 62.)
4 Hubbard further alleged that during the IDVP's CQA evalua-5 tion there was no review of the two selected contractors 6 QA/QC programs. (Hub. Dec. at 30.) This assertion is not 7 true. Mr. Sestak and Mr. Lundin stated as follows:
8 MR. SESTAK: "Mr. Lundin, the gentleman sitting next to me, will begin with a 9 review of the various check lists de-veloped for each contractor by the site 10 QA team and where appropriate identify areas related to criteria in 10 CFR 50, 11 Appendix B." (Attachment 5 at 12.)
l g 12 and:
( (3(
13 MR. LUNDIN: "I am Craig Lundin. As Frank mentioned, we were to review the 14 two contractors to assure that the ele-ments of the quality assurance program 15 were present for construction at that period of time, as well as to verify as 16 much as could be done the implementation of that quality assurance program.
17 In doing that we developed check 18 lists to work to. Four check lists were developed and utilized by the team at 19 the site. Two were verification check lists for actual inspection performed 20 and two were assessment plans to determine if the practices were in com-
) 21 pliance with the specifications and that
! they had a quality assurance program in 22 existence.
23 In development of these check lists, the specifications we used, the 24 quality assurance programs we used and other documents that would be appropri-to make this verification, (p 25 ate attributes developed can be associated with the elements of a quality assurance the 26
O 1 program as delineated in 10 CFR 50, Appendix B in that they were appropriate 2 for the scope of the contractor and asked the appropriate questions to 3 assure those functions such as inspection, training, material control 4 and other appropriate criteria that should have been applied.
5 They were not cross-referenced 6 specifically to those. However, they do relate in that we did assure that the 7 elements of that QA program were in ex-istence for that contractor scope of 8 work." (Attachment 5 at 13 and 14.)
9 In addition responding to a direct statement from Mr.
10 Hubbard, Mr. Lundin replied:
l 11 "There was no consideration of dif-ferences in quality and time, but only 12 to procedural systems and maybe the i level of compliance to those specific
~
13 things that were done. The level of quality was never considered to be 14 different than it would be today."
(Attachment 5 at 77.)
15 16 NRC Staff's Views 17 THe NRC's Systematic Assessment of Licensee 18 Performance (SALP) review for Diablo Canyon for the period 19 July 1, 1981 through December 1982 concluded:
20 "With the exception of your design control program, we find that your 21 performance of licensed activities is acceptable and directed towards safe 22 facility operation."
23 "Other aspects of your program appeared to have been adequately controlled 24 during the SALP period." (M.)
25 ///
26 ///
i O
tu) 1 Furthermore, the May 26, 1983 SALP Report 2 concludes:
3 "In general, the construction QA program appears to be well implemented and func-l 4 tioning in accordance with regulatory l requirements." (Enclosure 2 at 12.)
5 Additionally, Mr. R. Engelken, NRC Regional Admin-6 istrator, Region V, stated at the Cctober 20, 1982 Commis-7 sion Briefing that the CQA program at Diablo Canyon was an 8
adequate program and that the SWEC review was what Region V 9
had in mind in the Engleken to Denton March 1982 memo.
10 "Mr. Engelken: And the scope of that 11 (construction QA) audit is about what we had in mind. It is under way now at the 12 Present time." (Tr. at 9.)
0 13 14 "Mr. Engelken: We felt that in light of the Reedy Report and in light of our 15 findings when we initially did some inspection work out in the region 16 following the discovery of the error in the use of the diagram, we found that 17 there were discrepancies in the QA program. What gave us concern I think 18 was an apparent lack of top management involvement in the implementation of QA 19 in at least in some areas.
20 This did cast some sort of shadow over the general area of QA, quality 21 assurance, and this had been an issue raised by the intervenors. It had been 22 raised by the intervenors in hearing or prior to the hearing and it was denied 23 as a contention, as I recall it, but it was a lingering concern with them.
24 I thought that I didn't want to be in a 25 Position, since we had been inspecting O that plant through its construction, of 26 defending the QA for construction. I 1
l I thought it was appropriate for part of the reverification program to cover 2 quality assurance for construction even though our inspection program had 3 indicated that the construction QA program was an adeguate program and was 4 at least average and perhaps better than average than the program that we had 5 seen for construction at other facili-
! ties. But we did feel it would be a 6 further reassurance that there were no serious construction errors built into 7 the plant." (Tr. at 93-94.)
8 From the foregoing it is clear that the allega-9 tior;s and accusations made in the Hubbard declaration ring 10 hollow. Of the tens-of-thousands of potential findings and 11 observations possible (Attachment 5 at 23-24) only 1 finding i ~ 12 and 23 observatons were made. Directly contrary to the 13 generalized conclusions of Mr. Hubbard, PGandE and its 14 contractors had adequate construction QA programs. As 15 stated by Mr. Lundin, Chief Engineer of the SWEC Quality 16 Systems Division and a member of the FRC:
17 "We did determine and the information that was presented to us have evidence 18 to the fact that, No. 1, there were in the case of these two contractors 19 quality assurance programs in effect, No. 2, they were being implemented 20 because the evidence showed in the great majority of everything we looked at that 21 in fact these programs were complied with and, thirdly, the result of the 22 application of these programs resulted in our review of not finding anything in 23 the plant that was not in accordance with the intent of the specifications.
24 Those, I think, are the three key points
- ^ 25 which could probably be expanded upon, but the program was in place and it was 26 implemented, that is evidenced, and we n
U.
1 feel in the magnification that we used in looking at the plant itself that in 2 fact it essentially worked." (Attach-ment 5 at 53.)
3 4 Furthermore, Mr. C. O. Richardson, Jr., an 5 Engineering Manager with SWEC with many years of experience 6 in nuclear power plant projects who was also a member of the 7 FRC, agreed, on behalf of the FRC, at the same May 21, 1983 8 meeting that:
9 -
PGandE adequately controlled the activities of the construction 10 contractors, and 11 - There were aggressive corrective and preventive actions taken by r 12 PGandE and their construction contractors in implementing their
( 13 approved QA/QC programs. [ Ibid. at 81-82 and at 84.]
14
- 15 D. The Alleged "As-Built" Deficiencies Are Not Evidence Of Deficiencies In Con-16 struction Quality Assurance.
17 Movants cite discrepancies between plant 18 "as-builts" and piping design as evidence that " thoroughly 19 discredit the construction quality assurance product" (Gov.
l 20 Mot. at 11) and to " support the inference to be drawn from 21 more recent findings of deficiencies in design QA/QC."
22 (J. I. Mot. at 7.) The uncertainty in the boundary between 23 design and construction quality assurance that obviously l 24 exists in the Movants' minds (Gov. Mot. at 12) does not 25 exist in the personnel responsible for construction at l 26 Diablo Canyon nor has it ever existed (BME aff. at 2-7.)
r (O
1 Messrs. Bain, Manning and Etzler clearly describe 2 the procedures in effect throughout the history of Diablo 3 Canyon project to control "as-built" drawings and design 4 changes that are normal and inevitable in construction 5 activities. At Diablo Canyon, the General Construction 6 Department is responsible for "as-built" drawings and 7 obtaining prior approval from the Engineering Department for 8 design changes. Variances from approved design drawings are 9 not allowed without design change approval. General 10 Construction controls design changes and their documentation 11 by rigorous procedures. (BME Aff. at 3-5). The Engineering 1
12 Department is responsible for incorporation of "as-built" (O,O 13 changes into the final " record drawings" (BME Aff. at 14 6). 8/
15 The discrepancies between plant "as-built" 16 drawings and actual piping construction associated with the 17 IE Bulletin No. 79-14 walkdowns resulted from differences 18 between isometric drawings used by the Engineering 19 Department in design analysis and as-installed piping 20 ///
l 21 l 22 8/ At oral argument before this Board on April 14, 1983 the undersigned and Judge Johnson engaged in an ex-23 change regarding "as-builts". (Tr. at 203-205.) In reviewing that exchange it is apparent that Judge 24 Johnson was, in his questions and comments, referring to "as-builts" as prepared by construction personnel.
'S The undersigned while using "as-built" terminology
(. should have used the term " record drawing" in explain-26 ing the "as-built" drawing process.
O 1 systems. These differences resulted from the use of design 2 1sometric drawings which had not been updated by the 3 Engineering Department with "as built" information supplied 4 by General Construction. (BME Aff. at 7.) The 5 discrepancies identified in the walkdowns do not go to any 6 issue associated with construction QA/QC, but result from 7 the use of design isometric drawings which had not been 8 updated by the Engineering Department.
9 Similarly, discrepancies between "as-builts" and 10 actual field conditions as discovered by the IDVP resulted 11 from the use of unrevised record drawings which had not yet 12 been updated by the Engineering Department. Again, there is 13 no evidence that the "as-builts" as prepared by construction 14 were deficient. (BME Aff. at 7.)
i 15 E. Past Design Quality Assurance Deficien-cies Are Not Significant New Evidence of 16 Construction Quality Assurance Defi-ciencies Which Would Lead To A Different 17 Result.
18 On July 2, 1982 PGandE, in responding to a motion 19 to reopen the low power proceeding, dealt with the question 20 of why admitted deficiencies in design QA/QC were not 21 evidence of similar deficiencies in construction QA/QC 22 (PGandE Response to Joint Intervenors' Motion To Reopen The 23 Record, dated July 2, 1982, pp. 10-19, including supporting 24 affidavits of Richard S. Bain, and Warren A. Raymond et al.)
O 25 The argument following summarizes this earlier material.
26 ///
O 1 Attachments 1 and 2 to the Bain affidavit show 2 clearly that in 1968 and 1969 there were quality control and 3 quality assurance requirements placed on manufacturers and 4 contractors. Beginning in 1969, prior to the effective date 5 of 10 CFR Part 50, Appendix B (Appendix B), PGandE required 6 that each contractor performing work at Diablo Canyon have a 7 quality assurance program qualified to PGandE and NRC 8 requirements. (Bain Aff. at 5.) All contractors and 9 subcontractors or suppliers providing work at Diablo Canyon 10 adhered to these procedures in the performance of work at 11 the site or any other location affecting materials or 12 products ultimately destined for Diablo Canyon. (Bain Aff.
hs 13 at 5.)
14 The Bain affidavit establishes unequivocably that 15 site QA/QC activities were, except where deficiencies were 16 noted and corrected, in compliance with Appendix B at all 17 times material hereto. Quality control at the Diablo Canyon 18 site was a multi-tiered operation. (Raymond et al. Aff. at 19 14.) As a part of all bid specifications, each contractor 20 was required to prepare and staff a site quality 21 assurance / quality control organization adequate to inspect 22 the quality of work performed. PGandE field engineers and 23 inspectors reinspected this work for compliance with the 24 applicable design documents and specifications. The General
,, 25 Construction quality control on-site group was then directly 26 involved in the verification of the adequacy and effective-1 (O
1 ness of the contractors 8 quality assurance program and the 2 Company's following inspections. Finally, Corporate on-site 3 quality assurance engineers verified the adequacy and 4 effectiveness of the entire process. Further, QA/QC 5 Programs were implemented vigorously with adequate ratios of 6 inspectors and supervisors to craftsmen. Many QA audits 7 were performed on site and thousands of inspections were 8 Performed. Necessary " problem reports" were promptly filed 9 and followed up with the required corrective action. (Bain 10 Aff. at 5-6.)
11 PGandE started formal audits of construction 12 activities in December, 1969 when the QA Engineering 13 Department was originated. Construction audits were 14 conducted on a regular basis in accordance with NRC
- 15 regulations as described in the PGandE QA Manual. The i
16 corporate construction QA/QC audits from 1969 through 1981 17 exceeded 1500. This total does not include the hundreds of 18 audits conducted by individual contractors in accordance 19 with their QA programs nor audits by the NRC. (Raymond et 20 al_. Aff. at 6-7.)
21 There are various reasons why program deficiencies 22 in the area of design QA should not be indicative of the 23 quality of construction or the effectiveness of a 24 construction QA/QC program. QA programs for design and 25 construction activities function in significantly different 26 ways. In construction, one deals with a product
i
!(O l 1 (structures, systems, and components) which permits hands-on 2 type verification, such as inspection and testing. In 3 design, one deals with a " paper" product and verification 4 must be accomplished by measures such as checking, design 5 reviews, approvals, and/or limited testing. It is no i
6 accident that design quality has historically relied more i
7 heavily on professional judgment, and less on QA/QC
! 8 controls, than has construction. One important reason for 9 this has been the difficulty of developing methods for
! 10 design verification as effective as those available for 11 construction verification. (Raymond et al. Aff. at 11.)
{
12 For example, in applying the relevant criteria of 13 Appendix B there are differences between design and 14 construction in organizational structures and 15 responsibilities, verification approaches for assuring 16 design adequacy and product conformance, knowledge and l
l 17 skills required for QA/QC personnel, appropriate remedial 18 and corrective actions, and, most important, the process of 19 verifying adequacy and detecting deficiencies. PGandE 20 recognized these differences in the organization of the 21 original QA Manual. It was written to specifically address 22 the requirements of the various departments associated with 23 nuclear activities. One section of the QA Manual prescribed 24 engineering requirements (PRE); another section related to
, 25 construction work (PRC); and another section to procurement 26 of materials (PRP). Thus, the PGandE QA manual incorporated i
O 1 a set of separate requirements for engineering, procurement 2 and construction. (Raymond et al. Aff. at 11-12.)
3 The time span covered by formal construction 4 verification programs for DCPP is longer and the programs 5 are more detailed than in design. Construction controls 6 were easier to develop and implement than design controls.
7 For example, it was not until 1971 that ANSI N45.2 was 8 issued, and 1974 for ANSI N45.2.11 (the basis for Regulatory 9 Guide 1.64). These constituted the first industry wide 10 standards for design control QA requirements; and Regulatory 11 Guide 1.64 was the first on design control issued by the 12 NRC. As late as June 1976, Regulatory Guide 1.64, 13 Revision 2, was issued, further evolving the design control 14 guidance issued by the NRC to interpret Appendix B, Criteria 15 III. Previously, other requirements existed in codes and 16 other standards, or drafts thereof, but these were 17 relatively specialized and were not directed toward 18 management programs for quality. (Raymond et al. Aff. at 19 12-13.)
20 In contrast, fc,r construction activities at Diablo 21 Canyon, " quality assurance" requirements were an integral 22 part of every contract specification for construction, even l 23 those issued prior to the time Appendix B was issued for 24 comment in 1969. (Bain Aff. at 4. ) These requirements 25 covered the areas of testing, material procurement, v
]
26 inspection, reporting, personnel qualification, etc., either
/
l I
O 1 directly or by reference to detailed codes and standards.
2 These requirements were generally backed up by instructions 3 from the residents and superintendents and later formalized 4 in a GC manual. The requirements were further supplemented 5 by the ASME 'N' Stamp program used by contractors working on 6 the project. When formal QA programs became a requirement 7 for future nuclear work, the changes for construction 8 contractors at Diablo Canyon were significantly less than 9 the changes and additions required for design activities.
10 This was not unique to PGandE, but was characteristic of the 11 situation throughout the nuclear industry. (Raymond et al.
12 Aff. at 13.)
13 The Commission Order establishing Phase I of the 14 IDVP also included a requirement for an independent review 15 of the QA Programs for PGandE and its design consultants.
16 R. F. Reedy, Inc. ("RFR") performed this review for the IDVP 17 and submitted a Report dated March 8, 1982 (" Reedy Report").
18 The RFR effort had as an objective the identification of 19 design areas where the IDVP could most effectively 20 concentrate its efforts. (Teledyne Interim Technical Report 21 dated June 23, 1982.) To accomplish this objective Reedy 22 used present day interpretations and understandings of 23 Appendix B in place of the differing interpretations and 24 understandings applicable at the time work was done. This l 25 approach established a low threshold for the reporting of 26 ///
- 0 1 non-conformances or potential areas for investigation.
2 (Raymond et al. Aff. at 9.)
3 Hubbard relies heavily on the findings of the 4 Reedy Report both in his general condemnation of the PGandE 5 Quality Assurance program and his inference of " breakdowns" 6 in the construction QA/QC program. However, the Reedy i
7 effort was solely directed at quality assurance in the area of seismic design and did not involve site g construction 4
! 8 l
9 quality assurance. (Raymond et al. Aff. at 9.) This was 10 affirmed by Reedy at the meeting held in Bethesda, Maryland 11 April 1, 1983 as follows:
12
" .. .the seismic design QA review was not intended to and did not study the O'i- 13 complete PGandE QA program. The review as structured and reported is inadequate 14 to study the overall PGandE QA program
(
with regard to the construction and 15 operation.
16 Attempts to use the report as a commentary on activities not addressed 17 in the report can only lead to unsup-ported conclusions." [Tr. at 8, 9.]
18 19 The Governor's Motion (pp. 8-10) and the 20 supporting Hubbard declaration (p. 28) argue that it is 21 proper to infer that the construction QA/QC program must 22 contain inadequacies since the construction QA/QC personnel 23 reported to the same top management as the design QA/QC 24 Personnel whose program admittedly contained inadequacies.
25 However, this inference is not proper because it ignores the 26 completely separate and detailed functional organization l
l _ . _ _ . _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _. _ __._ _ .-- _
(
1 supporting the construction effort, which was headed by a 2 full vice president for general construction to whom the 3 construction quality control organization reported. This 4 construction quality control organization was in place 5 earlier, existed in greater detail, and was better staffed 6 than the design group. The two sides of the house were thus 7 more like two separate companies, and deficiencies in one 8 cannot logically be imputed to the other simply because they 9 both reported to the same senior management.
10 Finally an additional significant difference 11 between design QA/QC and construction QA/QC lies in the (5 12 inspection effort devoted by the NRC regional inspectors.
k] 13 As explained by Mr. Engelken at the November 9, 1981 meeting 14 before the Commission, the Regional inspection effort has 15 been devoted mainly to construction as opposed to 16 ///
17 ///
18 ///
19 20 21 22 23 24
(
26
I i
i O
1 design. 9/ This lends further credence to the assertion that 2 design QA/QC deficiencies are not significant new evidence 3 of CQA deficiencies because the latter were subjected to a 4 much more rigorous inspection which would have detected 5 deficiencies if they in fact existed.
6 ///
7 ///
8 /// ,
9 10 11 9/ COMMISSIONER AHEARNE: Have you had in 12 the past in your inspection history of O,' 13 Diablo Canyon during construction, have there been previous findings and en-forcement actions taken in this [ design]
14 area of quality assurance?
15 MR. ENGELKEN: Our program does not really include very much inspection in t
16 that particular area. That is a gap that has existed in our program. Ini-17 tially back in 1970 when the Appendix B criteria came out and were imposed on 18 construction efforts we inspected at that time to make sure that the company 19 did have a system for design review. We i established at that time that there was 20 a design review system and that it had l been implemented. That was what the i
l 21 program required of us at that time and we have fulfilled that requirement.
22 Through the years we have had some 23 inspection effort in that area, but rather limited compared with our on-site 24 construction inspection work. So it has been one of the weaker parts of our 25 inspection program, the general inspec-( tion of design review requirements.
26 [Tr. pp. 23, 24.]
m ht 1 F. Construction Quality Assurance Is Being Closely Adhered To In Ongoing Construc-2 tion.
3 Movants argue that the nature of current 4 construction activities has impacted the quality of those 5 activities. (Gov. Mot. at 22; J. I. Mot. at 14-15.) The 6 only support for these arguments are inferences drawn from 7 the size of the work force (Hubbard Supplemental Aff. at 8 12-13), alleged time pressures (Gov. Mot. at 23), certain 9 issues identified by Tennyson and Roam (J. I. Mot. at 14) 10 and notices of violation which have been issued by the NRC.
11 The Tennyson and Roam issues have been previously addressed p 12 in the instant response.
sj l
l 13 The Movants have taken ths relatively small number I
14 of Notices of Violation, all of the lowest severity levels, 15 that have occurred during the time that over 3-1/2 million 16 manhours of construction activity was ongoing and argue that 17 such findings are convincing evidence that PGandE did not l As l 18 and does not have an adequate construction QA program.
t 19 stated in the Affidavit of Mr. Amaral, the fact that
(
20 deficiencies are identified and corrected is an important 21 indicator that a QA program is working (Amaral Aff. at 4.)
i 22 Movant would have this Board believe that a small number of 23 Level IV and V Notices of Violation during a significant 24 period of construction is evidence that a construction QA 25 ///
26 ///
.O 1 Program is either non-existent or woefully inadequate. If 2 indeed that premise were true then a cursory review of 3 Notices of Violation issued to all other nuclear power 4 plants in this country would be a basis for reopening the 5 records for those plants not only for construction but also 6 for operation. At some point in this process, reason must 2
7 control and the heavy burden to justify reopening a record 8 must be met.
9 The aggressive CQA program at Diablo Canyon has lo resulted in over one hundred audits in the last nine months.
11 Although none of the audit findings were serious, they were 12 all reported to management to assure corrective action. The 13 fact that deficiencies in construction occur from time to 14 time is inevitable, but their identification and correction 15 is evidence that the QA program is working. The PGandE f
16 program for CQA contains necessary elements to achieve a 17 quality product and the evidence indicates it performs as 18 well or better than other programs in the industry. (Amaral 19 Aff. at 2-5.)
20 The nature of current construction activities at 21 Diablo Canyon has not impacted the quality of construction.
22 The modification work program is being conducted in a 23 planned and controlled manner and in strict compliance with 24 construction QA programs. The construction force is the 25 product of a comprehensive planning and scheduling effort to 26 assure that work activities are accomplished consistent with
O
- 1. a quality product. The construction force has a high ratio 2 of supervisory and inspection personnel with effort directed 3 in the specific plant area where responsibility is 4 established to adequately supervise the manual workers. The 5 containment area, which is on the critical path, has a well 6 supervised construction force to ensure the required quality 7 product. (BME Aff. at 8-10.)
8 The recent increases in construction manpower have 9 been accompanied by a parallel increase in the number of NRC 10 inspections. Only one item of noncompliance which dealt 11 with deficient workmanship has been identified. PGandE has l
l 12 fully addressed this item and it had been earlier identified 13 by PGandE's QC and QA Departments who were developing 14 corrective actions at the time of the NRC inspection. (BME 15 Aff. at p. 11-12.) Nine other NRC inspections during the 16 recent construction activities did not identify any other 17 items of noncompliance dealing with deficient workmanship, i 18 but instead demonstrated that the CQA program is fully 19 functional. (BME Aff. at p. 15.)
l 20 Additionally, NRC Region V conducted a special
! 21 investigation of concerns raised by the Tennyson and Roam 1
22 statements. (Attachment 2.) While three items of apparent 23 non-conformance were identified, the vast majority of the l 24 concerns were not substantiated. One noncompliance involved
/G . 25 the removal of " red tags" by the QC inspector after it was U 26 verified that proper corrective work had been taken and l
1 accepted. The existing procedures had required an 2 administrative step prior to removal. This administrative 3 oversight did not, in any way, affect the quality of 4 construction and the procedures have subsequently been 5 revised to allow removal of red tags when the inspector 6 accepts the corrective action work. (BME Aff. at 12-13.)
7 A second noncompliance was identified in a 8 welder's current qualitications. PGandE has subsequently 9 determined that the welder's qualifications were in 10 accordance with applicable standards due to the welder's 11 work in the previous six months (BME Aff. at 14). The third
, 12 noncompliance involved the renewal process for welder l'
13 qualification. In the instance cited, the welding foreman 14 who was incorrectly kept current on the active welders list 15 did not perform any production welding during the 16 qualification period in question. The qualification renewal 17 procedures are being clarified to preclude any future 18 misinterpretation and PGandE is verifying that the improper 19 qualification renewal process was never used for production 20 work. (BME Aff. at 14.)
l 21 In summary, counsel for the Governor rather 22 cavalierly argues that the parties "are entitled to a i 23 hearing on quality assurance in the present round of 24 construction -- a topic on which they have had no previous 25 opportunity to a hearing." Once again counsel shows a lack 26 of understanding of how the licensing process is supposed to
rh b
1 work. If the above argument were correct, every time "new" 2 construction ..(or modifications) were undertaken a party 3 would be allowed to reopen a clos'ed record whether or not 4 the tests for reopening a closed record and late-filed 5 contentions were met. As discussed, infra, it is this same 6 naivete regarding' the hearing process that leads Governor's 7 counsel to argue that reopening the record on construction 8 quality assurance would not delay these proceedings.
9 III 10 THERE IS NO LEGAL BASIS .TO REOPEN THE RECORD FOR TEE TAKING OF EVIDENCE ON 11 CONSTRUCTION QUALITY ASSURANCE.
e 12 A. The Motion Does Not Address A Signifi-(I cant Safety Issue Nor Would The 13 '
" Evidence" Supplied By Movants Lead To A Different Result.
14
, 15 As noted supra, p. 8, and in'PGandE's July 2, 1982 e
s 16 Response'To Joint Intervenors' Motion To Reopen The Record 17 (pp. 24-34) the Movants have a he mj burden to meet in order 18 to sustain the reopening of a closed record for considera-19 tion of a late filed. contention. M/ The arguments which 20 ///
21 ///_
22 ///
23 24 W In our July 2, 1982 Response (pp. 24-34) we articulated the legal principles governing the reopening of closed records and the admission of late- filed contentions.
25 ,Rather than repeat those. principles and their overall b a application to this case, we will incorporate them by 26 reference. -
, . . m .
x -
t t
t O
1 must be met in order to reopen any closed record have been 2 definitively spelled out as follows:
. 3 . , "The motion must be both tinely present-
\ ed and addressed to a.significant safety 4 or environmental issue. . .Beyond that, it must be established that 'a different 5 result would have been teached initially had [the material submitted in support 6 of the motion] been considered.'" [ Wolf Creek, supra p. 338.]
7 8 In each instance we have demonstrated that the I
9 facts relied upon *by Joint Intervenors and the Governor are 10 Joither not as stated, or that the inferences from those 11 facts are not logically or technically sufficient to warrant 12 a reopening. To argue that the subject matter is (iv) 13
~
construction quality assurance and that the subject is 14 obviously a significant safety issue simply begs the 15 question. The question must be whether the evidence brought 16 forward by movants, considered in light of all the facts; 17 .(1) gives rise to . a significant safety issue, and (2) 18 whether a different result would have been reached had all of the facts now known been known at the time of the initial
~
a 1
19 20 decision. Movants have neither established that the 21 " evidence" they have b::ought forward raises a significant 22 safety issue nor have tney met their burden of establishing 23 that the facts now known would have brought about a 24 different result if considered initially.
25 ///
U 26 ///
O YJ 1 B. Should The Record Be Reopened On Con-struction Quality Assurance An Undue And 2 Prejudicial Delay Will Result.
3 Counsel for the Governor maintains that a 4 reopening of the record of construction Quality Assurance 5 would not cause a delay in these proceedings. Such a 6 position is simply preposterous to anyone who has been 7 involved in proceedings of this nature before. As an 8 example, the most recent discovery requests propounded by 9 the movants in the area of Design QA has taken up thousands 10 of manhours of the Licensee's time and will result in the 11 production of thousands of documents. Should a similar 12 request be directed to the Licensee in the area of CQA, the 13 time involved to respond and the number of documents to be 14 produced would be increased by at least an order of
! 15 magnitude. Counsel's position is even more transparent when 16 one looks closely at what he means by " reopening the 17 record." What he is requesting is an independent 18 construction review program to " assure" CQA. At page 30 of 19 his Motion, he states that 20 "The only way to assure the quality of construction at Diablo Canyon is to 21 conduct a statistically valid review of all construction activities." [ Emphasis
! 22 alfded. ]
23 The motion goes on to state that 24 "this review can be completed without interfering with commercial operation."
25 ///
26 ///
1 Again, such statements are simply not within the realm of i
2 reality. The " review" as set forth at page 30 of the ,
3 Governor's Motion would, in and of itself, require many l
4 months, if not one to two years, to complete. This position 5 makes the request indistinguishable from the position of the 6 Joint Intervenors whose avowed purpose has always been to 1 delay operation of Diablo Canyon ad infinitum.
8 Perhaps the one statement which reflects a candid, 9 albeit perhaps unintentional, intent is found at p. 32 of
. 10 the Governor's motion where the following appears:
11 "All this motion seeks is the opportu-nity to test fully the utility's claim
) 12 that it has now put its house in
- (_,/ order -- a test the Governor agrees need i
13 not delay commercial operation if, as the company asserts, no deficiencies 14 remain to be found." 11/
1 15 A similar intent was expressed by counsel for Joint l 16 Intervenors at the oral argument on April 14, 1983. (Tr.
17 pp. 150 11. 8-15 and p . 166 11. 5-7.) The net result of 18 giving effect to these stated issues would be to permit the 19 movants to go on a " fishing expedition" concerning l
20 construction quality assurance at Diablo Canyon. This in 21 spite of overwhelming evidence that construction quality 22 assurance at Diablo Canyon was in place and functioning 23 ///
24 n _1_1/
1 PGandE does not accept the assertion that ' As noted
. . . it
('j 25 [PGandE] has now put its house in order. '
l previously, our construction quality assurance " house" 26 has always been "in order."
a 1 properly from the beginning of construction activities in 2 the late 1960's.
3 To support this position movants have taken a 4 number of disjointed and isolated occurrences involving 5 relatively minor deficiencies in construction activities at 6 Diablo Canyon and attempted to infer that major deficiencies 7 existed in construction activities at Diablo Canyon. They 8 have cited instances where the quality program has 9 functioned as intended i.e., cases where deficiencies were 10 discovered and corrective action taken and attempted to 11 transform them into examples of so-called " major breakdowns 12 of construction quality assurance." As such, they have i J 13 engaged in a classic attempt "of making a mountain out of a 14 molehill." It is respectfully submitted that not only have 15 they failed in that endeavor, they have totally failed to i
t 16 meet their burden to reopen the record. It is respectfully 17 requested that the motions to reopen these proceedings for 18 ///
19 ///
l 20 ///
i 21 22 23 l 24 lC 2s 26 l
i t
l
A
!U 1 the taking of evidence on construction quality assurance be 2 denied.
3 4 Respectfully submitted, 5 ROBERT OHLBACH PHILIP A. CRANE, JR.
6 RICHARD F. LOCKE Pacific Gas and Electric Company 7 P.O. Box 7442 San Francisco, California 94120 8 (415) 781-4211 9 ARTHUR C. GEHR Snell & Wilmer 10 3100 Valley Center Phoenix, Arizona 85073 11 (602) 257-7288 12 BRUCE NORTON (g-w)
(, Norton, Burke, Berry & French, P.C.
13 P.O. Box 10569 l
Phoenix, Arizona 85064 14 (602) 955-2446 l
15 Attorneys for Pacific Gas and Electric Company 16 17 18 By w Bruce Norton 19 20 DATED: May 31, 1983.
21 22 l 23 24
(
26 l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION h
(j
( the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-275
) Docket No. 50-323 Dicblo Canyon Nuclear Power Plant, )
Units 1 and 2 )
)
CERTIFICATE OF SERVICE The foregoing document (s) of Pacific Gas and Electric Company has (have) been served today on the following by deposit in the United States mail, properly stamped and addressed:
Judge John F. Wolf Mrs. Sandra A. Silver Chairman 1760 Alisal Street Atomic Safety'and Licensing Board San Luis Obispo CA 93401 US Nuclear Regulatory Commission W2thington DC 20555 Mr. Gordon Silver 1760 Alisal Street Judge Glenn O. Bright San Luis Obispo CA 93401 Atomic Safety and Licensing Board US Nuclear Regulatory Commission John Phillips, Esq.
Wn:hington DC 20555 Joel Reynolds, Esq.
Center for Law in the Public Interest ge Jerry R. Kline 10951 W. Pico Blvd. - Suite 300
- atomic Safety and Licensing Board Los Angeles CA 90064 US Nuclear Regulatory Commission Wnchington DC 20555 David F. Fleischaker, Esq.
P. O. Box 1178 Mrc. Elizabeth Apfelberg Oklahoma City OK 73101 c/o Betsy Umhoffer 1493 Southwood Arthur C. Gehr, Esq.
l l San Luis Obispo CA 93401 Snell & Wilmer 1
3100 Valley Bank Center Jenice E. Kerr, Esq. Phoenix AZ 85073 Public Utilities Commission State of California Bruce Norton, Esq.
5246 State Building Norton, Burke, Berry & French, P.C.
350 McAllister Street P. O. Box 10569 son Francisco CA 94102 Phoenix AZ 85064 l Mre. Raye Fleming Chairman
! 1920 Mattie Road Atomic Safety and Licensing Sh211 Beach CA 93449 Board Panel US Nuclear Regulatory Commission l Mr. Frederick Eissler Washington DC 20555 Scenic Shoreline Preservation Conference, Inc.
3 More Mesa Drive
( ta Barbara CA 93105
'1 airman Judge Thomas S. Moore h[ .tomic Safety and Licensing Chairman Appeal Panel Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Wnshington, D.C. 20555 US Nuclear Regulatory Commission Washington, D.C. 20555 S cretary US Nuclear Regulatory Commission Judge W. Reed Johnson Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Attn: Docketing and Servicing US Nuclear Regulatory Commission Section Washington, D.C. 20555 Lawrence J. Chandler, Esq. Judge John H. Buck Jack R. Goldberg, Esq. Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Office of Executive Legal Director US Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Richard B. Hubbard Commissioner Nunzio J. Palladino MHB Technical Associates Chairman 1723 Hamilton Avenue, Suite K US Nuclear Regulatory Commission San Jose, CA 95125 1717 H Street NW Washington, D.C. 20555 Mr. Carl Neiberger
_legram Tribune Commissioner John R. Ahearne
( . O. Box 112 US Nuclear Regulatory Commission San Luis Obispo, CA 93402 1717 H Street NW Washington, D.C. 20555 Commissioner Thomas M. Roberts US Nuclear Regulatory Commission Commissioner Victor Gilinsky 1717 H Street NW US Nuclear Regulatory Commission Wnshington, D.C. 20555 1717 H Street NW Washington, D.C. 20555 l Michael J. Strumwasser i Counsel to the Attorney General Commissioner James K. Asselstine 3580 Wilshire Blvd. Suite 800 US Nuclear Regulatory Commission I
Los Angeles, CA 90010 1717 H Street NW Washington, D.C. 20555
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,y s and El ctric Company Pacific h_nte: May 31, 1983 l
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lO EXHIBIT 1 l
! AFFIDAVIT OF RICHARD S. BAIN, JAMES R. MANNING, and RICHARD D. ETZLER l
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O 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 4
5 6
In the Matter of )
7 ) Docket No. 50-275 PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-323 8 )
Diablo Canyon Nuclear Power Plant )
9 Units Nos. 1 and 2 )
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10 11 AFFIDAVIT OF RICHARD S. BAIN, 12 JAMES R. MANNING, AND RICHARD D. ETZLER 13 O' STATE OF CALIFORNIA )
14 ) ss.
CITY AND COUNTY OF SAN )
15 FRANCISCO )
16 17 The above being duly sworn, depose and say:
i 18 Our names are Richard S. Bain, James R. Manning 19 and Richard D. Etzler. We have had various management 20 responsibilities for construction activities at Diablo 21 Canyon since 1969. Mr. Etzler is Project Superintendent for 22 Diablo Canyon construction activities at the jobsite. Mr.
l 23 Manning is Construction Superintendent for Diablo Canyon 24 construction activities at the General Office. Mr. Bain is l 25 Manager of Station Construction in the General Construction O 2e Department. A summary of Mr. Mennin9's and Mr. Etz1er's 1
O 1 qualifications are attached to this affidavit. Mr. Bain's 2 qualifications were previously filed on July 2, 1982 as part 3 of PGandE's response to a motion to reopen the low power 4 proceeding.
5 We have carefully read the affidavit and 6 declaration of Mr. Richard B. Hubbard dated March 26, 1983 7 and May 8, 1983 filed with the Governor's Motion dated 8 May 17, 1983. We will address our comments specifically to 9 Mr. Hubbard's allegations of a breakdown of quality 10 assurance and quality control in the construction activities 11 associated with "as-built" drawings and recent modifications 12 at Diablo Canyon. As we will comment hereinafter, a 13 comprehensive and vigorous on-site construction quality l 14 assurance / quality control program is now, and has been, in 15 place and implemented. This program was, and is, subjected 16 to numerous PGandE and NRC audits during construction 17 activity at Diablo Canyon. Absolutely no such breakdown of l
l 18 construction quality assurance and quality control as Mr.
19 Hubbard alleges has occurred.
20 I 21 "AS-BUILT" DRAWINGS l 22 PGandE has recognized the need for "as-built" 23 drawings and control of design changes since the beginning 24 of construction activities at Diablo Canyon. PGandE 25 Standard Practices, which were in effect prior to the start 26 of Diablo Canyon, specified the method for changing drawings
O 1 and provided the distribution for the "as-built" drawings.
2 At Diablo Canyon, additional direction was given in various 3 other instructions and procedures to assure transmittal of 4 design changes and "as-built" drawings to the Engineering 5 Department for incorporation on " record drawings."
6 For the purpose of clarity, PGandE uses the term 7 "as-built" when referencing the information generated by 8 General Construction in the form of a marked-up drawing, 9 sketch or revised design data that portrays the condition as 10 installed in the plant. This "as-built" information is 11 forwarded to the Engineering Department for incorporation on 12 the record drawings. A record drawing is a design drawing that has been assigned a record number and has been issued O
14 by the Engineering Department.
15 In the early stages of Diablo Canyon, before 16 issuance of PGandE's Diablo Canyon Quality Assurance Manual 17 on December 29, 1970, Standard Practice 410.2-1 was followed 18 to provide the Engineering Department with the "as-built" 19 Plant condition. Attached to this affidavit as Attachment 1 20 is a complete file of on-site drawing control procedures 21 that have existed since the beginning of the job to the 22 present. For example, the first document of the attachment 23 dated April 6, 1970, addresses the handling of "as-built" 24 drawings at Diablo Canyon and attaches an earlier PGandE 25 memorandum addressing this same issue dated July 30, 1968.
O 2e These attached procedures c1 ear 1r specify in 9 teat detai1
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1 the General Construction responsibility for the control of 2 design changes and submittal of "as-built" information to 3 the Engineering Department for incorporation on record 4 drawings.
5 These procedures clearly indicate a recognition 6 for the need to control design changes and "as-built" 7 information and have been in place and fully implemented 8 throughout the construction of Diablo Canyon. These 9 procedures are the implementing instructions to meet the 10 requirements of the Diablo Canyon Quality Assurance Manual 11 and are updated and revised in accordance with Construction, 12 Engineering, Quality Assurance, and regulatory requirements.
O 12 ^ careful review of the attechment wi11 c1eer1r and 14 conclusively show the evolving process that has been ongoing 15 to assure that design changes are controlled and the 16 "as-built" plant condition documented.
17 The adequacy of implementation of these procedures 18 has been verified by continuing audits of the entire design 19 drawing control process by the General Construction Quality 20 Control Department, by PGandE Corporate Quality Assurance 21 Department, and by NRC inspections. These audits have 22 consistently verified that programs existed, that they were 23 adequate, and their implementation was effective.
24 Construction forces, including supervisors, Field Engineers 25 and Inspectors of contractors and PGandE, have always 26 recognized the need that the construction work shall comply
O with approved drawings. Variances from approved design 1
2 drawings are not allowed without design change approval.
3 Control of design changes and their documentation by General t >
4 Construction is through the design change control and 5 "as-built" procedures. Work cannot proceed without 6 compliance with approved drawings. When installation work l 7 does not meet design drawing requirements, work stops until 8 necessary design changes are approved.
9 The on-site contractors involved with work 10 requiring quality assurance were required as a part of the 11 PGandE specifications to prepare quality assurance programs 12 and quality control procedures. These contractor procedures O 13 incorporate the requirement for each contractor to have a V
14 Program for controlling design changes and preparation of 15 "as-built" information. These programs and procedures were 16 reviewed and approved by PGandE prior to commencement of 17 work; and as referred to above, have also been subjected to 18 numerous audits.
19 It should be noted that consistent with standard 20 industry practice for construction and applicable procedures 21 from the Engineering Department, it is not necessary to l 22 Prepare "as-built" drawings for all construction work. For i
23 example, certain installations such as raceways and l
24 instrumentation tubing are not typically required to be 25 "as-built." In these cases, the Engineering Department O 2e wou1d provide design requirements specifyin9 terminal points
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O 1 and general design details. The specific placement and 2 routing is left to the discretion of field construction 3 forces. At Diablo Canyon these " field run" commodities were 4 subsequently walked down to assure compliance with changing S criteria.
6 In other cases, the Engineering Departaent 7 furnishes criteria and installation tolerances within which 8 variances do not require design change approval or drawing 9 "as-builts." Any changes in installation work outside of 10 these Engineering Department specified construction 11 tolerances would require design change approval and 12 "as-built" drawings. Variances from design drawings O 13 requirins "as-bui1t" sketches and drawin9s are turnished to
- 14 the Engineering Department by General Construction. The 15 Engineering Department has final authority on which sketches 16 and "as-built" changes require incorporation on record i
17 drawings and require design review.
18 Mr. Hubbard, in his affidavit and other l
19 submissions, has referred to the results of the IE Bulletin 1 20 No. 79-14 walkdown which identified differences between 21 design isometric drawings for piping systems and 22 as-installed piping systems as evidence of a breakdown in 23 the construction quality assurance process. This view is
! 24 incorrect. Piping is not installed to design isometric 25 drawings but is installed in accordance with the piping and l
O 2e mechanical area drawings. These area drawings prescribe to l
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O 1 General Construction how and where piping and piping system 2 components such as valves, flanges, branch lines, and 3 fittings are to be located. The piping installation 4 contractor prepares erection isometrics from the area 5 drawings. The construction design change and "as-built" 6 drawing control programs are applied to these contractor 7 erection isometrics. As required by Engineering Department 8 criteria, any variances requiring design change approval and 9 "as-built" drawings are processed in accordance with 10 Construction Quality Assurance and Quality Control 11 Procedures and "as-built" drawings are forwarded to the l 12 Engineering Department for review and incorporation on the C 13 appropriate drawings.
14 The Engineering Department utilizes design 15 isometric drawings for piping system analysis work. These 16 design isometric drawings are not issued or used for 17 installation. IE Bulletin 79-14 required that licensees is review the design analysis with the "as-built" piping. At 19 Diablo Canyon there were variances found between the piping 20 as installed to the area drawings (erection isometrics) and l
21 the design isometric drawings. The IDVP also found similar 22 variances. As stated earlier, variances from the area 23 drawings were approved and "as-builts" were furnished to the 24 Engineering Department for updating or for incorporation on 25 the area drawings. These changes to the area drawings O
2e require time for drewing updating and reissuence. Chenees
O 1 on area drawings were not systematically incorporated in the 2 design isometric drawings. The constructed "as-built" 3 piping condition simply cannot be compared with the design 4 isometric drawing for purposes of judging Construction 5 Quality Assurance and Quality Control Programs.
6 II 7 ADEQUACY OF CURRENT CONSTRUCTION FROGRAM AND CONSTRUCTION QUALITY ASSURANCE PRO-8 GRAMS TO SUPPORT PRESENT MODIFICATION WORK.
9 10 Mr. Hubbard has inferred from the nature and pace 11 of new construction at Diablo Canyon and a recent NRC Notice 12 of Violation that there has been a breakdown in construction Q 13 quality assurance. This allegation is not the case. The 14 modification work program is being conducted in a planned 15 and controlled manner consistant with strict compliance to 16 the Construction Quality Assurance Program. An evaluation 17 of the NRC Notices of Violation clearly demonstrate that the 18 QA/QC programs are fully functional.
19 The Project organization has a planning and 20 scheduling department both in the home office and on-site.
21 The Project home office planning and scheduling group 22 furnishes the site with forecasts of work in all commodities 23 and disciplines. The site planning and scheduling group l 24 prepares forecasts of manpower requirement forecasts versus 25 time based on historical unit rates to accomplish the work O 26 activities consistent with quality, priority and schedule
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- o 1 requirement. The construction management uses this planning 2 and scheduling information to allocate overall manpower '
3 needs and also to assign the types and numbers of 4 supervisory and support personnel.
5 The planning and scheduling organization assists 6 the construction supervisors with planning and laying out of 7 daily activities. This planning and scheduling activity 8 assures that the construction effort proceeds in a carefully 9 planned, organized, and controlled manner consistent with a 10 quality product.
11 The recent (December 1982 to mid May 1983) 12 increase of the construction work force at Diablo Canyon was 13 accomplished in a planned and controlled manner with an i 14 adequate buildup of non-manual personnel assigned to 15 supervise the manual work force. Throughout this period a 16 ratio of supervision to workers has been maintained 17 typically at 1 foreman to every 10 craftsmen. When 18 superintendents, field engineers, inspectors, Q. C.
19 engineers and Q. C. inspectors are all considered, the one 20 to ten ratio reduces to a one to two ratio of non-manual to 21 manual workers. In fact, the ratio of non-manual to manual 22 workers has been approximately one-to-two over the history 23 of the Project except during certain periods such'as the 24 first half of 1982 when the ratio was approximately 25 one-to-one. Historically at Diablo Canyon, this ratio meets O 2e or exceeds that for typice1 nuc1 ear p1 ant construction.
O 1 Additionally, the construction effort is directed 2 into specific areas wi th specific responsibilities '
3 established to carefully control manual work. For example, 4 in the Unit #1 Containment, where construction is on the l
, 5 critical path to completion, there has been approximately 75 l 6 pipefitters working on pipe supports on both the day and 7 swing shift, 45 iron workers working on annulus structural l
8 steel on the day shift and approximately 20 on the night 9 shift, 20 iron workers working on equipment access platform 10 modifications on day shift and 10 on the swing shift; and 40 11 iron workers working on both the day and swing shift on the 12 Polar Crane modifications. Summarizing, a total of 180 13 manual workers are in the Containment on day shift and 145 14 on the swing shift. When one realizes that only 180 workers 15 are performing the modifications within the entire area of 16 Containment, which is on the critical path, one can see that 17 this is a reasonable number which can be, and is, adequately 18 controlled.
19 The Plant has been divided into areas of l 20 responsibility and for each of these areas, the General l 21 Construction Department has assigned a Superintendent 22 responsible for that area and correspondingly there are i
- 23 contractor superintendents for the same areas.
i 24 Responsibilities are further subdivided into assistant i
25 superintendents, general foremen and foreman areas of l
O 26 responsibility. Therefore, the number of workers on the l . _ . _ _ . - _ _ . _ _ . _
O 1 Project when viewed as a whole could appear to present a 2 Problem of supervision; but, as described above, the work 3 force when looked at in discreet slices of time and location 4 is indeed capable of being properly managed.
5 The recent increases in manpower to accomplish the 6 present work commenced in December of 1982. From that time 7 to the present, approximately 3,700,000 manhours of work has 8 been expended. During this same period of time, the NRC has 9 increased their inspection activity approximately 80% over 10 that which was accomplished over the prior year. Since 11 December 3, 1982, through May 20, 1983, the NRC has 12 conducted ten separate week long intensive inspections of 13 construction and modification activities. These inspections 14 have included examination of procedures, work process, final 15 product and associated documentation.
16 Resulting from these 10 NRC inspections, only cae 17 item of ncncompliance was identified which dealt with 18 deficient workmanship. The item pertained to structural 19 steel work in the Unit #1 Fuel Handling Building. PGandE's 20 responses to this Notice of Violation substantiates that the 21 deficiencies in welding identified in this structure had not 22 been overlooked by PGandE's ongoing QA/QC program. While 23 certain welding deficiencies were accepted by the contractor 24 QC inspectors, they were under investigation by PGandE's QC 25 and QA Departments. PGandE had identified the deficiencies O 2e prior to the sub3ect NRC inspection and they were
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1 appropriately documented and appropriate corrective measures 2 were being developed at the time of the NRC inspection.
3 PGandE's response to the NRC Region V Office dated May 19, 4 1983 is attachment 2 to this affidavit.
5 On May 19, 1983, NRC Region V issued a report of 6 its investigation of concerns raised by V. Tennyson and 7 R. Roam, former employees of the H. P. Foley Company 8 (Foley), contractor to PGandE. The concerns revolved around 9 the adequacy of quality assurance and quality control 10 programs at Diablo Canyon. The Region V concluded that the 11 vast majority of the concerns were not valid. The NRC 12 special inspection did identify three items where H. P.
Q 13 Foley failed to comply with certain procedural requirements 14 of its QA program. These resulted in two Level IV 15 violations and a Level V violation. The Level V violation 16 concerned a procedural non-compliance in regard to 17 processing and control of a non-conformance. The Level IV 18 violations concerned non-compliances regarding welder 19 qualification and qualification renewal procedures for 20 welders. Each of those Notices of Violation are 21 specifically addressed below.
22 The Level V violation concerns the removal of red 23 tags from nonconforming items. Red tags are an 24 administrative identification of items not in conformance 25 with quality requirements. Fifteen structural steel beams O 2e in the unit No. 2 fue1 hand 11ng hui1 ding hed been te99ed O
1 nonconforming due to gouges on the flange surfaces. The 2 discrepancy was documented on a Foley nonconformance report 3 and corrective action was taken. On ten of the beams where 4 corrective action had been completed, the Foley quality 5 control inspector verified that proper physical corrective 6 work had been taken and had accepted the corrective work as 7 being complete. The red tags were removed by the inspector 8 at this time which was not in accordance with the Foley QC 9 procedure. The procedure required an administrative step 10 between inspection-acceptance and removing tl.e red tags.
11 The inspector should have had the non-conformance report 12 " corrective action complete section" signed off by the Foley l
Q 13 Project Manager prior to removal of the red tags. It should 14 be noted that there was no technical concern with the work 15 or corrective action. The contractor has since revised his 16 procedures to allow removal of red tags when the inspector i 17 accepts the corrective action work.
l 18 The first Level IV violation pertains to one 19 individual welder's qualification period. The particular l
20 welder was shown on the active welders' list, i.e.,
1 21 currently qualified. The NRC found that the welder's record I 22 did not substantiate that the welder had in fact kept his 23 qualifications current. This welder's work was reviewed 24 over the six months prior to January 27, 1983, and it was l 25 found that the welder had in fact been welding on production O 2e m O 1 work and, consequently, was currently qualified in 2 accordance with standards and procedures.
3 The second Level IV violation cited an instance of 4 an improper qualification renewal process used to keep a 5 welding foreman current on the active welders' list. This 6 foreman did not perform any production welding during the 7 qualification period in question. PGandE is verifying that 8 this improper qualification renewal process was never used 9 to qualify or requalify any welders doing production work.
10 In addition, the Contractor's qualification renewal 11 procedures are being clarified to preclude any future 12 misinterpretation of the procedure requirements.
Q 13 The NRC, in their special inspection resulting 14 from these allegations, performed interviews with quality 15 control inspectors and could not substantiate any cases of 16 inspector intimidation. The one instance referred to in 17 these allegations where an inspector claimed to have been 18 harassed by an iron worker was investigated by PGandE. It 19 has been determined that the harassment was not work related 20 and that the iron worker was in fact terminated as a result l 21 of the harassment.
22 Only one of the ten NRC inspections during this 23 time period resulted in an item of non-compliance which 24 concerned deficient workmanship. Nine of the ten NRC 25 inspections during this time period did not result in items O 2e of noncomp11ance resulting from deficient workmenship.
O 1 Rather than erroneously infer that the construction QA 2 Program has " broken down" because of one Notice of Violation 3 Pertaining to minor welding deficiencies, the proper 4 inference is that the QA program is fully functional since 5 the problem had been previously identified and corrected by 6 PGandE. Mr. Hubbard also failed to take into account the 7 numerous other inspections that covered the vast majority of 8 the modification work. These inspections included 9 examination of work on piping supports, ventilation duct 10 supports, electrical raceway supports and annulus structural 11 steel modifications. These inspections in fact, identified 12 that the construction QA/QC programs were in place and Hubbard has presented an Q 13 adequately implemented. Mr.
14 evaluation that is totally skewed and is not reflective of 15 an objective view of quality assurance implementation.
16 It has been a policy of PGandE at the Diablo 17 Canyon site to give priority to quality ahead of production.
18 From the beginning to this date this policy has been 19 ///
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O 1 regularly explained in meetings with contractors, PGandE 2 personnel, and others performing work at the site.
3 4 Dated: May 31, 1983 6 , ,
Rithifa S. Bain 7
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h 9 J s R. M&nning 10 11 Richard D. Etz'ler'
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12 Subscribed and sworn to 14 before me this 31st day of May, 1983 15 16 .
17 (Nancy J. Lemaster, % SEAL Notary Public in and
! 18 for the City and County of San Francisco, 19 State of California.
My commission expires l 20 April 14, 1986.
2I ;:xxxxxxxxxxxx<mxxxxxxxxx'<xx;;
l NANCY J. LEMASTER y
- jh, d4,4 ;0TARY PUBUC-CALIFORNIA 9 f
CirY AND COllNTY OF x 23 . SAN FRANCISCO My Commission Expres Apnl 14,1986 xxxxxxxxMxxxxxxMW 74 25 O 2e l
O 1 PROFESSIONAL QUALIFICATIONS OF 2 RICHARD D. ETZLER 3
4 5 My name is Richard D. Etzler. I am Project 6 Superintendent at Diablo Canyon. I have held this position 7 since September 1978. I am responsible for managing the on 8 site construction and startup activities at Diablo Canyon.
9 Prior to my duties as Project Superintendant, I 10 was Resident Mechanical Engineer. I held that position from 11 March 1977 to September 1978. As Resident Mechanical 12 Engineer I was responsible for managing the mechanical type O 13 of construction activities such as insta11etion of 91 rin9.
14 ventilation systems, turbine / generator components and 15 nuclear steam supply system components.
16 Prior to my duties as Resident Mechanical Engineer I
( 17 I was a Field Engineer and Group Leader reporting to the i
18 Mechanical Resident Engineer. I held this type of position 19 and level of responsibilities from 1971 to 1977. My 20 responsibilities included supervising installation of the 21 nuclear steam supply and turbine generator systems.
22 Prior to my duties as a group leader for the
( . 23 Mechanical Resident Engineer I was a Startup Field Engineer t
( 24 beginning in December 1969. My duties as a Startup Engineer l 25 included preparing preoperational startup testing procedures 26 and scheduling tests.
O 1 Prior to my assignment to Diablo Canyon I was in 2 training to be a startup engineer since October 1968. This 3 training included approximately 9 months startup experience 4 at the Robert E. Ginna nuclear power plant near 5
Rochester, NY and 6 weeks reactor operator training at 6 Westinghouse's Waltz Mill facility near Pittsburgh, FA.
7 Prior to October 1968 I was a field engineer at 8
PGandE's Round Mountain 500 kv Substation for 3 months.
9 Duties included planning construction activities, "as built" 10 drawings and assisting in testing components.
11 My first assignment with PGandE was as a Field
, 12 Engineer on the Construction of the Moss Landing Power Plant
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] 13 Units 6 and 7. This assignment started in June 1967 and 14 continued to July 1968. My duties included assuring 15 installation of piping systems was in accordance with 16 engineering specifications and drawings.
17 I graduated from California Polytechnic College, 18 San Luis Obispo in June 1967 with a BS in Mechanical 1 19 Engineering.
20 21 22 23 24 25 O 2e
i O 1 PROFESSIONAL QUALIFICATIONS OF.
y 2 JAMES R. MANNING 3
4 5 My name is James R. Manning. I have been Station 6 Construction Superintendent with the General Construction 7 Department in the Pacific Gas ~ and Electric Company since
< 8 September 1978. In October 1982 I assumed the '
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9 responsibilities for the construction of Diablo Canyon Power 10 Plant. Prior to October 1982 I ' was responsible for-11 construction activities involved with fossil and 12 hydroelectric generating plants and transmission and .
Q 13 distribution substations. ;
14 I was Records Management Supervisor in the Company' 15 Quality Assurance Department from July 1977 to September _
l 16 1978. In this capacity I was responsible for the 17 establishment of a nuclear records management system in 18 compliance with ANSI N45.2 for both Diablo Canyon and 19 Humboldt Bay nuclear power plants.
20 Between March 1976 to June 1977 I was Resident 21 Engineer in charge of all Station Construction work at 22 Pittsburg, Contra Costa, Avon, Oleum and Martinez Power 23 Plants. During this period I was responsible for 24 supervising the construction of the pump stations on.. the 25 Richmond to Antioch fuel oil line in addition to other O 26 construction activities.
I O 1 s From June 1972 to March 1976 I was the Staff s
2 Engineer to the Station Construction Superintendent 3
responsible for the construction of Diablo Canyon. In this 4
capacity I was responsible for coordinating engineering, 5
material and Quality Assurance matters between the on-site 6
construction forces and the appropriate General Office 7 Departments.
8 From the time of my initial employment with 9
Pacific Gas and Electric Company in July 1969 until June 10 s 1972 I was the Office Engineer at Diablo Canyon Power Plant.
11 In this capacity I was responsible to the Project 12 Superintendent for Scheduling, Cost Control and Engineering 13 Services which included preparation and implementation of 14 the on-site drawing control procedures.
15 Prior to my employment with Pacific Gas and 16 Electre Company I was a commissioned officer on active duty
( ' 1,7 with the U. S. Army Corps of Engineers for nine years l
18 attaining the rank of Major. During this time I was l
19 responsible for a variety of construction projects in the 20 U. S., Europe, and Korea.
21 I attended the University of California at 22 Berkeley, California from 1956 to 1960 majoring in 23 Industrial Engineering until I was commissioned into the 24 Army Corps of Engineers.
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O ATTACI! MENT 1 OF EXHIBIT 1 IIISTORICAL FILE OF DRAWING CONTROL PROCEDURES i
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O ATTACHMENT 2 OF EXHIBIT 1 PGandE's SUPPLEMENTAL RESPONSE Dated May 19, 1983 i
! To
! March 29, 1983 6 NOTICE OF VIOLATION I l
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PACIFIC OAS AND E LE C T RIC C O M PANY
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May 19, 1983 Mr. John B. Martin US Nuclear Regulatory Commission, Region V 1450 Maria Lane Suite 210 Walnut Creek CA 94596 Re: Docket No. 50-275, OL-DPR-76 Diablo Canyon Unit 1
\ Dear Mr. Martin d
Region V issued a Notice of Violation (Severity Level IV) on March 29, 1983 to Pacific Gas and Electric Company. Enclosed is PGandE's supplemental response to that Notice. An initial response was submitted on April 25, 1983.
Very truly yours, -
Enclosure-cc w/ encl: Service List
PG8E SUPPLEMENTAL RESPONSE TO MARCH 29, 1983 NOTICE OF VIOLATION i
On March 29, 1983, NRC Region V issued a Notice of Violation as a result of inspections conducted from February 28, 1983 through March 4,1983. The Notice of Violation concerned construction work performed on the Fuel Handling Butiding structural steel by H.P. Foley Company (Foley), a contractor to PG8E. PGandE responded to the Notice of Violation on April 25, 1983 (attached). The response included descriptions of corrective actions to be taken by PG8E as a result of the NRC inspection, as well as another inspection perfonned by PGandE's Quality Control (QC) Department. One corrective action described in the April 25 response specified a reinspection to be performed by PG8E of 10% of the fillet welded connections in the Unit 1 Fuel Handling Building. The 10% reinspection has been completed. This report is a supplement to PGandE's April 25, 1983 response and includes discussions of additional background information, the results of the reinspections, analysis of the findings of the reinspections, and further corrective action taken beyond those specified in the April 25 report.
In particular, the Quality Assurance (QA) and Quality Control programs for both PGandE and Foley were in effect and fully functional during the time period that the Fuel Handling Building structural steel modifications were being performed. The first PG8E QA audit of structural steel work was conducted in December,1982. Between that time and the time that the NRC Notice of Violation was issued, the PG8E QA Department has conducted ten audits on this type of work. The audits covered such items as design package preparation and approval, qualification of inspectors, inspection records, deficiency reports, and weld rod control. Six of these audits were of the construction process and physical work, including verifying ongoing corrective actions. Specifically, between February 7 and 11,1983, the PG8E QA aaaa. .aaaaa pano 1 of a
Department ccnduct;d threa audits of the fuel handling building work to verify effective corrective actions from previous audits. These included reviewing qualifications of inspectors, the process of design changes, and welding problems.
The results of the audits indicated that Foley was effectively implementing its quality program, although a few of the audits indicated a concern with weld inspections. Consequently, PG8E's General Construction OC Department perfonned a surveillance inspection from February 17, 1983 to March 24, 1983 of structural steel fillet welds.
The surveillance inspection found various discrepancies which were documented on a Non-Confonnance Report. These discrepancies agreed with or were similar to the findings of the NRC as reported in the Notice of Violation at approximately the same time. Therefore, PG4E directed Foley to perform a reinspection in the Unit 1 Fuel Handling Building of at least 10% of all fillet welds, in order to further define any welding descrepancies. Four hundred and eighty-nine of a total of approximately 3,870 fillet welds were reinspected. Four hundred and two of the reinspected welds were found to be acceptable, and 40 of the 489 welds were found to have some minor degree of variance from acceptance criteria. These minor variances were appearance deficiencies, such as rough welds, undercut that was marginally over acceptance criteria, small arc strikes and welds that were marginally below minimum size allowed by the acceptance criteria. The remaining forty-seven of the 489 welds were unacceptable. Excessive undercut, undersize welds and welds which did not have complete fusion were included in this group.
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nnom innoto Page 2 of 4
Thus, this 101 sampling program showed that about 9.6% of the reinforced welds did not meet acceptance criteria. The deficiencies could not be isolated to O specific connection types, individual welders or inspectors, or locations that would have allowed pinpointing any further discrepancies. Therefore, PG8E decided to expand to a 1001 reinspection of structural steel fillet welds in the Unit 1 Fuel Handling Building. The reinspection program showed that approximately 14% of the welds did not meet acceptance criteria, and all of these have been reworked to meet criteria.
PG8E has investigated the findings of the reinspection program and has determined that there are two principle causes of the structural steel welding deficiencies. The first is insufficient training of new welders and new welding inspectors, in that they did not receive sufficient familiarization with all the acceptance criteria and that strict compliance with the criteria was required. The second is an insufficient ratio of QC inspectors to production workers; this resulted from an undesirable distribution of inspectors, lack of good supervision of the contractor Quality Control group, and was to some degree influenced by the build-up in the number of workers.
Additionally, it was also found that three QC inspectors had not been properly qualified.
Strong measures have been taken by Foley at the direction of PG8E to correct deficiencies with the Foley quality program. Since mid-March 1983, Foley has conducted over 30 training classes on welding and welding inspection criteria for QC inspectors, welders, and the welders' foreman. The average experience level of new QC inspectors has increased from 21 months in the January and February period to 86 months in April, with an average overall now of 50 months experience. The ratio of QC inspectors to workers has been increased nnom innoso Page 3 of 4
from 1 in 25 to 1 in 10. The time available for inspection by inspectors has been increased by providing more support in aktnistrative work activities.
Foley has introduced new, but strong and experienced, management into its QC/QA organization that will provide the necessary leadership to the organization. Their first action was to review all inspector qualifications and require recertification.
Further, the following additional action has been taken by Foley management.
In particular, Foley is monitoring the number and activities of craft workers to be certain that the activities are fully supported by trained and qualified inspectors. This applies across the board in all areas and types of quality-related work.
To assure that any possible generic implications of the inspection findings are addressed, PGandE has directed Foley to perfonn a 100% fillet weld reinspection in the hot shop and Unit 2 portions of the Fuel Handling Buf1 ding, and a 10% fillet weld reinspection in the Unit 1 Containment Annulus Structure for work perfonned from January 1983 to mid March 1983. In addition, weld work accepted by Foley inspectors who were found not suitably qualified will be sampled. This sampling will include ventilation duct support modifications and electrical raceway support modifications.
PG8E will advise the NRC, Region V, of the results of these further reinspection and sampling programs.
l
hACIFIC OAS AND E LE C T RI C C O M PANY 77 BE ALE STREET, S AN FR ANCISCO C ALIFORNI A 94106 TE LE PHONE (415) 7814213 FOWS 3 P. O. B Ox 7 4 4 2. S A N FR AN CISCO, C ALIFORN aa 94120 TELECOP8ER (415) 543 7813 cos a nt opeLe Ac.e ca mi.. .v . .s.a. .m..:,
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April 25, 1983 Mr. John B. Martin, Regional Administrator US Nuclear Regulatory Commission, Region V 1450 Maria Lane Suite 210 Walnut Creek CA 94596-5368
% Re: Docket No. 50-275, OL-DPR-76
, Diablo Canyon Unit 1 Response to Notice of Violation -
NRC Inspection Report 83-08
Dear Mr. Martin:
NRC Inspection Report 50-275/83-08, dated March 29, 1983, included a Notice of Violation (Severity Level IV) . PGandE's response to this Notice is enclosed.
Very truly yours, -
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pGandE'o RESPWSE '10 NOTICE & VIG.ATIN IN NRC INSPECTIN REpWT 50-275/83-08 O l i
On March 29, 1983, NRC Region V issued a Severity Imvel IV Notice af Violation as part of PRC Inspection Report 5&275/83-08 on Diablo Capron Unit 1.
This Notice cited the failure of H. P. Foley, a KrandE contractor, to perfom wod in accorchnee with pmcedures or code requirunents and a deficiency in the training program for welders and welding Quality Control Inspectors. 'Ibe violation was described in the Notice as follows:
[ As a result of the inspectim conducted on February 28 . March 4,1983, and in accordance with the NRC Enforcanent Policy (10 CFR Part 2, Appendix C), 47 FR 9887 ()hrch 9,1982), the following violation was identified:
10 CFR 50, Appendix B, Criterico V, as implemented by Section 17.1.5 of the FSAR and the MandE Quality Assurance Manual Section V states in part that, " Activities affecting quality shall be l prescribed by dommented instructions, procedures, or drawings...and i shall be acceplished in accordance with these instructions, procedures, or drawings..."
'Ihe Noward P. Foley Quality Control Procedure for AWS Di.1 Welding, QCP-5A, Revision 8, references in paragraph 2.0 the latest edition of AWS D1.1 (the Structural Welding Code) as the O applicable code for structural steel welding.
AUS D1.1-1982 in paragra;b 3.6.1 states that, "The faces of fillet welds may be slightly convex, flat, or slightly concave as shown in Figures 3.6(A) and (B) with none of the unacceptable profiles shown in Figures 3.6(C)", and in paragraph 8.15.1.3 that, "All craters are filled to the full cross section of the weld."
( AE D1.1-1982, "Ocznentary on Structural Welding-Steel", paragraph 6.5,
" Inspection of Work and Records", states in part that, " Die
! stamping of welds is not recanended since die stamp marks may fom sites for crar:k initiation."
The Howard P. Toley Quality Control Pmcedure for AWS D1.1 Welding, QCP-5A, Revision 8, states as follows:
paragraph 5.2, "Each welder shall be assigned a unique numbered and lettered identificatim stamp."
paragraph 5.2.1, "Each welder shall stamp his identification number in the proximity of his weld, in sufficient quantity to effectively identify his woh."
- paragraph 9.1, " Welds shall confom as closely as practical O to design requireiments and exposed faces of welds shall be reasonably smooth and regular."
- paragraph 11.1, "Ench welding inspector shall be assigned a unique I.D. stamp."
paragraph 11.1.1, "Each welding inspector will stamp in
. sufficient quantity to identify the accepted work."
paragraph 11.5.1.4, " Fillet welds may be 1/16 inch undersized, ,
providing that the undersized portion does not exceed 10% of '
the total length of the veld."
paragrsph 11.5.1.7, '*Ibe veld shall be clean and free of slag." ]
Contrary to the above the NIC Inspector found several procedural violaticos at the 182' elevatim of the Unit 1 Fuel Handling Building. 'Ibese violations concerned welder and Inspector identification stamps and weld deficiencies.
The violations were listed in a table and the Notice concluded with the following:
[ All of the above velds had been examined and accepted by H. P. Foley's Quality Control Inspectors on or before February 7,1983.
' Ibis is a Severity Invel IV violation (Supplanent II). ]
Statement of Explanation The H. P. Foley Ccopany has in place approved procedures which delineate the responsibilities and methods required to execute and verify specific activities which affect the quality of components, equipnent, material and 4
services requiring Quality Assurance.
Regarding the NRC Inspector's finding on the stamping of the welds, the Code (ASW D1.1) does not require the welder's idatification stamp but does require the Inspector's stamp. 'Ibe contractor's procedure (QCP-5A), however, requires that both the welder's identification stamp be affixed in the proximity of his weld "in sufficient quantity to effectively identify his work", and requires that the Inspector's identification stamp be affixed "in sufficient quantity to identify the accepted work".
Six welds were identified as having no welder identification stamp or weld inspector's identification at each veld. We believe the requirements of AWS D1.1 and procedure QCP-5A were interpreted too strictly. Neither the code nor the procedure require a weld inspector's stamp for each weld.
The welds on the connectims in question were so closely spaced that one weld inspector's identification stamp would be sufficient to identify the acceptance of all the welds in the welded connectics. In the cases noted, the identifistion stamp serves only as tenporary traceability because the welded connections are painted upon final acceptance of the weld. 'the welder and the weld inspector are presently traceable to each veld by the Work Traveler and the Weld Inspection Sheets. 'Ibese are retained as a lifetime document-at the plant. Neither the code nor the procedure explicitly state the meaning of " sufficient quantity". The contractor's procedure O willinspectors be revised to provide a more consistent criteria for welders and to fo11ce.
Regarding the NRC Inspector's finding on the acceptability of the welds, 3GandE has determined that certain corrective actions are appropriate.
These are described in the following sections.
Corrective Steps Taken and Results Achieved PGandE initiated a discrepancy report inmediately upon confimatie of the weld discrepancies noted my the Region V Inspector on March 4,1983. In addition, the Quality Control Department perfomed an expanded inspectim aimed at detemining the extent of occurrence of similar discrepancies. As a result of this inspection, Nonconfomance Report No. DC(F83-RC-N001 has been issued.
i Corrective Steps Which Will Be Taken The following are the corrective steps which will be taken:
- 1. H. P. Foley Procedure QCP-5A will be revised to clarify the requirenents for stamping of welds by welders and inspectors.
- 2. Training of H. P. Foley Welders and Quality Control (QC)
Inspectors will be reviewed and additimal training conducted to assure familiarity with inspection requirsoents.
- 3. A reinspection of 10% of the cmpleted welded connectims for the Unit 1 Fuel Handling Building modifications shall be conducted. The results of the reinspectim will be documented and attached to Nanconfomance Report No. DCXFB3-RC-N001.
- 4. Filler metal shall be added to the identified undersize welds as mquired to meet design and weld profiles in accordance with AWS D1.1.
- 5. The craters identified at the weld end teminatim will be renoved by grinding and additimal filler metal added where required.
- 6. Slag will be renoved where identified and the weld will be reinspected.
- 7. In the fillet velds in which the welder had stamped his identificatim number on the weld, the identification numbers shall be renoved from the weld by grinding. Reinspecti m will assure that the weld size is acceptable.
- 8. 'the fillet veld which was identified as 1/8" undersize shall have filler metal added as required by design requirements.
Date When Full Capliance Will Be Achieved Revision of Procedure QCP-5A will be ocupleted by May 8,1983.
'!he review of the training program and additimal training of welders and O QC Inspectors will be empleted by May 6,1983.
The reinspection and all weld repair will be completed by May 15, 1983.
f 1 i
EXHIBIT 2 AFFIDAVIT OF JOHN M. AMARAL l
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l UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 4
5 6
In the Matter of )
7 ) Docket No. 50-275 PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-323 8 )
Diablo Canyon Nuclear Power Plant )
9 Units Nos. 1 and 2 )
)
10 11 12 AFFIDAVIT OF J. M. AMARAL l
13 14 STATE OF CALIFORNIA )
) ss.
15 CITY AND COUNTY OF SAN )
FRANCISCO )
16 i 17 18 The above being duly sworn, deposes and says:
19 My name is John M. Amaral. I am Manager of 20 Quality Assurance for Bechtel Power Corporation (Bechtel) 21 and have 30 years of industry experience. I would like to 22 comment on the adequacy of construction quality at the 23 Diablo Canyon plant.
I 24 In my position I regularly evaluate the status and 25 adequacy of quality programs for nuclear power plants, 26 including construction at those facilities. I review 1
i 1 reports of activities conducted by quality personnel at the 2 construction site or home office that include results of 3 daily monitoring and formal audits of the applicable 4 elements of the quality assurance program. I also review 5 and consider the results of NRC inspections and client 6 audits in assessing overall program implementation.
7 The adequacy of construction quality at the Diablo 8 Canyon Nuclear power plant is reflected by numerous audits 9 and reviews that have been conducted at the construction 10 site. To begin with, PGandE has implemented an aggressive 11 program of audits (supplementing numerous audits conducted 12 by contractors) concerning the procedures and work 13 activities at the construction site to assure that
~
14 contractors are following their required programs. These l
15 are performed by personnel independent of project 16 activities. Over one hundred (100) of these audits have 17 been conducted in the last nine months. Findings are
- 18 reported to the management of the functions audited and to 19 project management to ensure correction. Although none of 20 the findings were determined to be of serious consequence, 21 adequate attention is given to corrective action to see that 22 a high level of quality is maintained in work practices.
23 Further evidence of adequate quality assurance 24 program implementation is found in the results of the NRC, 25 Region V, Systematic Assessment of Licensee Performance 26 (SALP) Report, Docket Number 50-275, 50-323, dated March 25,
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1 1983. The functional construction areas examined by the NRC 2 were evaluated to be in control and the construction QA 3 program "to be well implemented and functioning in 4 accordance with the regulatory requirements."
5 Noncompliances identified during the period covered by the 6 SALP review of work related to construction and construction 7 QA program were categorized Severity Levels V. Prompt 8 corrective measures taken by PGandE and the contractors were 9 found to be satisfactory by the NRC.
10 Stone & Webster Engineering Company (SWEC) was 11 employed to evaluate and verify the quality of work 12 performed by Wismer & Becker (W&B) (NSSS piping installation 13 etc.) and G. F. Atkinson (GFA) (civil / structural work in (O,/ 14 containment) on Unit 1.
15 This review was accomplished by independent 16 auditors and inspection specialists under contract to 17 Teledyne Engineering Services (TES), the Independent Design 18 Verification Program (IDVP) Program Manager. An exhaustive 19 review of documentation was performed by SWEC. Completed 20 construction work was examined and determined to be 21 adequate. The review team concluded that both GFA and W&B 22 as-constructed work conformed to the design requirements.
23 It was also concluded by SWEC that PGandE adequately l 24 controlled the contractors and installation activities. The t
1 25 number and significance of the (1) finding and (23) 26 observations is decidedly less than might have been expected l
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. l 1 from such an extensive review program and compares most 2 favorably with experience elsewhere in the industry.
3 Over a million individual inspection operations 4 are typically performed during construction involving the l
5 combined efforts of contractors, NRC and utility inspection 6 personnel. A selected number of these are reperformed or 7 independently audited. Confidence that a high level of
. 8 quality is in fact achieved on Diablo Canyon is given by the
! 9 low number of significant discrepancies detected by this 10 close scrutiny.
11 It is clear, from the above, that construction on 12 the Diablo Canyon Nuclear Power Plant has met the higil 13 standards expected. PGandE has adequately implemented a 14 quality assurance program to ensure continued quality of 15 construction. Where there have been mistakes, the utility 16 has taken prompt action to correct them.
17 Despite all efforts to prevent them, deficiencies 18 will occur from time to time. It is the purpose of a QA 19 program to control them, and prevent them from causing e 20 problems which will endanger public health and safety. A QA 21 program cannot be expected to result in zero deficiencies or 22 findings.
23 The fact that deficiencies are identified and 24 corrected is an important indicator that a QA Program is 25 working. A properly structured construction QA Program 26 includes thorough inspections of in-process and completed
i 1 work to confirm compliance with requirements and to identify 2 and document deficiencies, and audits by an independent 3 quality assurance group to assure that the inspection 4 process is effective and to identify program weaknesses.
5 Items identified may be administrative or procedural in 6 nature, but are documented nevertheless. The identification 7 and documentation of deficiencies is essential to 8 formulating and taking corrective actions to preclude 9 recurrence in subsequent work and to informing management of 10 quality status so that proper actions at the management 11 level can be taken.
12 Some perspective is important on the significance 13 of the several construction quality programs for contractors 14 and PGandE which provide defense-in-depth for quality.
15 Primary responsibility for quality of work is placed on the 16 organization performing the work through holding craftsmen 17 and their management accountable for work quality. Next, 18 the quality control program provides for full inspection 19 that is planned and documented. In turn, the entire process 20 is monitored and controlled by the quality assurance 21 program, through audits, over inspections, and various 22 management functions to assure quality. Finally, 23 surveillance is given by the NRC (and other outside 24 entities, in some cases) through frequent inspections. The 25 functioning of each of these programs may be thought of as 26 screening-out some fraction of deficiencies, and preventing 1 recurrance of others, so that those which remain are neither 2 numerous or significant.
3 In my view, the PGandE program for construction 4 quality does contain the necessary elements to achieve these 5 goals, and the above evidence indicates it had performed as 6 well (or better) than other programs in the industry to 7 achieve good quality construction.
8 9 Dated: May 31, 1983 10 11 . / ?? .
[J. M. Amaral 13 14 Subscribed and sworn to I'
before me this 31st day 15 of May, 1983 16 1 _
17 *#'
7 Neficy J. Lemaster 7 '
18 SEAL Notary Public in and for the City and County 19 of San Francisco, State of California.
20 My commission expires April 14, 1986.
21 22 Q;xxxxxxxxxxxxxxxxxxxxxxxxxxxy x NANCY J. LEMASTER l
l 23 h C' g 7,Ef NOTA'W PUGUC CAUF05: fila CITY AND COUNTY OF SAN FRANCISCO 24 My commission Expires Apnl 14,1986 XXXXXXXXXXXXXXXXXXXXXXXx 25 26 O
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1 PROFESSIONAL QUALIFICATIONS OF 2 JOHN M. AMARAL 3
4 5 My name is John M. Amaral. I am the Manager of 6 Quality Assurance for the Bechtel Power Corporation. In 7 this capacity I have responsibility for advancing the 8 effectiveness of the corporate program and directing its 9 implementation in all four divisions of Bechtel Power 10 Corporation. This covers quality control and related 11 activities for engineering, construction, and procurement.
12 As part of this, I have provided special assistance to 13 several projects including non-Bechtel projects, where 14 quality problems have developed, in which I directed 15 investigations, furnished consulting services, and developed 16 recommendations for corrective action.
17 I have 30 years of industry experience, including 18 11 years with Bechtel. Previously, my responsibilities 19 included Manager of Quality Assurance for the Gaithersburg 20 Power Division, Deputy Manager of Division Quality Assurance 21 in Bechtel's San Francisco Power Division, and Quality 22 Assurance Manager for the LMBR Fast Flux Test Facility.
23 Prior to joining Bechtel, I was Manager of Quality 24 Systems for Aerojec Nuclear Systems Company, and served as a 25 consultant on reliability, quality systems, and N 26 non-destructive testing and developed the quality system for
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1 Aerojet's portion of a major nuclear program. Earlier, I 2 was program manager of advanced technology, responsible for 3 conducting research and development programs in 4 nondestructive testing and reliability. Before that, I held ;
5 successive positions as Quality Engineer, Manager of Quality 6 Engineering, and Associate Manager and, later, Manager of 7 Reliability and Quality Assurance. I have also been Chief 8 Engineer at Burndy Corporation, responsible for supervising 9 production engineering and control and quality control.
10 I hold a Bachelor of Science degree from the 11 University of Southern California, where I majored in 12 Industrial Management / Engineering. I am a Registered 13 Professional Engineer in California and a Certified 14 Reliability Engineer by the American Society for Quality 15 Control (ASQC). I am a Senior Member of the ASQC; Junior l 16 Past Chairman of the ASQC Energy Division; Member of the 17 Atomic Industrial Forum Subcommittee,on Quality Assurance; 18 and Member of the General Requirements Subcommittee of the 19 ASME Committee on Nuclear Quality Assurance. I was selected 20 as ASQC Energy Division QA Person of the Year for 1982, and 21 received the 1983 American Nuclear Society ( ANS) Special 22 Award for distinctive quality assurance achievement in the 23 nuclear energy field.
24 25 26 O
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O I EXHIBIT 3 UNITS 1 AND 2 DIABLO CANYON SITE FINAL SAFETY ANALYSIS REPORT Page 3,1-4 and Table 3.2-1 i
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3.1.2 OVERALL PLANT REQUIREMENTS Criterion 1 - Quality Standards (Category A)
Those systems and components of reactor facilities which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences shall be identified and then designed, fabricated, and erected to quality standards that reflect the importance of the safety function to be performed. Where generally recognized codes or standards on design, materials, fabrication, and inspection are used, they shall be identified. Where adherence to such codes or standards does not suffice to assure a quality product in keeping with the safety functions, they shall be supplemented or modified as necessary. Quality assurance programs, test procedures, and inspection acceptance levels to be used shall be identified.
A showing of sufficiency and applicability or codes, standards, quality assurance programs, test procedures, and inspection acceptance levels used is required.
Discussion All systems and components of Diablo Canyon Units 1 and 2 are classified N according to their importance in the prevention and mitigation of accidents.
Those items vital to safe shutdown and isolation of the reactor or whose failure might cause or increase the severity of a loss of coolant accident or result in an uncontrolled release of excessive amounts of radioactivity are designated Class I. Those items important to the reactor operation but not essential to safe shutdown and isolation of the reactoi or control of the l
release of substantial amounts of radioactivity are designated Class II.
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Those items not related to reactor operation or safety are designated Class III.
1 Class I systems and components are essential to the protection of the health j and safety of the public. Consequently, they are designed, fabricated,
! inspected and erected and the materials selected to the applicable provisions
! of recognized codes, good nuclear practice and to quality standards that l
I reflect their importance. Discussions of applicable codes and standards as l
Amendment 4 3.1-4 (February 1974) l
O O O TABLE 3.2-1 SEISMIC CLASSIFICATION OF STRUCTURES, SYSTEMS AND COMPONENTS FOR DIABLO CANYON SITE Design Class II Design Class III Design Class Design Class I Plant features important to reactor Plan t features Plant features important to safety, Applicability including plant features required operation. but not essential to not related to safety, including plant features reactor opera-to assure (1) the integrity of the reactor coolant pressure boundary, not required to assure (1) the tion or safety.
(2) the capability to shut down the integrity of the reactor coolant reactor and maintain it in a safe pressure boundary, (2) the capabil-shutdown condition, or (3) the ity to shut down the reactor and capability to prevent or mitigate maintain it in a safe shutdown con-the consequences of accidents dition, or (3) the capability to which could result in potential prevent or mitigate the con-of f-site exposures comparable to sequences of accidents which could the guideline exposures of 10 CFR result in exposures comparable to 100. the guidelines exposures of 10 CFR 100.
- 1. Quality Standards - Plant 1. Quality Standards - Plant features required to meet AEC features not required to meet Requirements GDC-1. AEC GDC-1.
- 2. Quality Assurance - Plant 2. Quality Assurance - Plant features required to meet features not required to meet Appendix B to 10 CFR 50. Appendix B to 10 CFR 50.
Seismic Design - Plant 3. Seismic Design - Plant features
- 3. not required to meet AEC GDC-2 features required to meet AEC GDC-2 and proposed Appendix A and proposed Appendix A to 10 to 10 CFR 100. Plant features CFR 100. Plant features not designed to withstand effects designed to withstand effects of Double Design Earthquake of Double Design Earthquake (DDE). (DDE).
d O ATTACHMENT 1 1
NRC INTERVIEW OF VIRGIL H. TENNYSON Dated March 25, 1983 l
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UNITED STATES OF AMERICA w '
2 NUCLEAR REGULATORY COMMISSION 3 INTERVIEW OF VIRGIL H. TENNYSON 4 .
5 Conference Room 100 Van Ness Street 6 19th Floor San Francisco, California 7
Friday, 8 March 25, 1983 9
10 The above interview was held at 1:57 p.m.,
11 Pursuant to notice. s -
12 BEFORE:
13 EUGENE J. POWER, ESQ.
THOMAS W. BISHOP, ESO.
C'z- ) 14 JOHN F. BURDOIN, ESQ.
'^'
U.S. Nuclear Regulatory Commission 15 1450 Maria Lane Suite 210 16 Walnut Creek, California 94596
- 17 YALE I. JONES, ESQ.
Counsel for Virgil H. Tennyson i
18 Jones, Brown ar.d Clifford 100 Van Ness Street, 19th Floor g 19 San Francisco, California s u i 20 '3, A7 I$ II i 21 ,h>
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3 WITNESSES: DIRECT CROSS REDIRECT RECROSS 4 VIRGIL H. TENNYSON 4 -- -- __
5 6
7 8 IDENTIFIED IN EVIDENCE EXHIBITS:
9 None 10 . .
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1 PROCEED 1NGS
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2 MR. POWER: Today is March 25, 1983 and the 3 time is 1:57 p.m. This is an interview of Phr. Virgil H.
< 4 Tennyson who is a former Quality Assurance Manager for 5 Foley Electric Company at Diablo Canyon Nuclear Generating 6 Station, Avila Beach, California.
7 This interview is being conducted in the law
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8 office located on the 19th floor at 100 Van Ness Avenue, 9 San Francisco, California, 10 The purpose of.the interview is to discuss with s
11 Mr. Tennyson his knowledge of the installation activities 12 of Foley Electric Company at the Nuclear Construction site
. 13 and any other possible, if any, wrong doings at the site.
i \_/ [.) 14 My name is Eugene J. Power. I an an investigator ,
15 with the United States Nuclear Regulatory Agency. This
16 individual is Mr. Thomas W. Bishop. He's Chief, Reactor
- 17 Project Branch, Region V, United States Nuclear Regulatory I
j 18 Commission. On my right is John F. Burdoin, I.ead Inspector i
19 also out of Region V, United States Nuclear Regulatory 0
j 20 Commission. Also present during this interview is Mr. Yale I .
21 Jones, attorney for Mr. Tennyson.
f 22 And Mr. Tennyson, are you willing to be interviewed a
j 23 at this time?
24 MR. TENNYSON: Yes, I am.
25 MR. POWER: Are you , dill ing to be interviewed l.V
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[ ' -t ) 1 i l l under oath?
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2 MR. TENNYSON: Yes, I am.
3 MR. POWER: Would you please stand and raise 4
your right hand?
5 Whereupon,
'O VIRGIL H. . TENNYSON 7 wr.s called as a witness by the Regulatory Staff, having E been first duly sworn, was examined and testified as 9 follows:
10 DIRECT. EXAMINATION 11 . .BY MR. POWER:'
12 0 .7or the pur' poses of identification, would you
. 13 please state your full name and present residence?
I,:
w x_,) 14 A My name is Virgil F. Tennyson, and I reside 15 at 1220 North School Street, San Marina, California.
16 Q And what was your present or last position with
- 17 Foley Electric Corporation?
[. 18 A Quality Control Manager.
g 19 0 And for what period of time did you occupy that l 20 position?
f 21 A Aperiodofaboutapproximatelheightyears, I 3
j 22 guess, but during that eight years of manager I was possibly l 2
,i 23 three years of it or nore Quality Assurance and Quality 24 Control Manager.
25 Q And do you recall specifically where you have I N
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\ () 1 now had the title, the last three years, can you give an V '
- . 2 approximation of just the one quality assurance manager? -
8 3 A -I'm sorry, I didn't -- what are you asking?
4 Q Do'you know specifically how long you have held 5 this last position?
6 A As Qua,lity Control Manaaer?
7 Q Yes.
8 A Well, I have been for the last eight years.
9 Q Oh, ?otal?
10 A Yes. . .
s -
ii Q And Quality Assurance?
12 A The dates, I don't know --
. 13 'O Approximately -- I'm not interested in tying you
) 14 down to a specific -- I'm just trying to get a feel for 15 your association and knowledge of Foley Electric?
16 A Well, during that interim of eight years as
. 17 manager, I'd say three, three years of it or better was j 18 quality assurance manager, too.
- 19 Q Okay.
j 29 A At one time they called r Luality Director.
(j 21 Q Primarily just a cht.i., of citle rather than L
3 f 22 responsibility?
ie I
!' 23 A Yes.
l 24 Q In generalizations now, can you give us' a brief 25 description of what your duties have entitled, specifically
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'(f')T s_ 1 'over the last few years?
i 2 MR. JONES: Do you want him to describe separately i 3 the quality control function and the quality assurance 4 function?
5 MR. POWER: It doesn't make any difference to I 6 me. No, he can put them together. We're interested in 7 mostly in what your responsibilities were over approximately 8 the last three years.
9 THE WITNESS: The last three years. Well, during to the last three years I would have been involved in quality s
11 assurance and quality control or over it. My responsibilities 12 were to hire and train inspectors, quality engineers. I
.3 13 was in charge of doing spec review and writing procedures
' \&' ') 14 in accordance with the necessary codes and required codes 15 and standards, evaluating the procedures and distributing 16 and controlling the distribution of them, in having, enforcing 17 the inspection in the field of the installations, to the g
j 18 procedures. That's about it.
i 19 BY MR. PONER:
- 20 0 Can you give an average figure of the number of c m h 21 individuals that you have supervised, say, within the 22 last three years. I don't know if that's gone up or down
.. f i*
l 23 drastically or not. I 24 A It has fluctuated from probably 30 inspectors 25 down to like 12 and then back up to very recently here we've .
l
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, -y -- - ., . -%.- -- --- --
I 7 I
O)
( 1 gone to about a hundred and I think when I left out there 2 it was 140 some. That's total quality control personnel.
3 Q So up to this 130 or 140, were they under your 4 supervision?
5 A Yes.
6 Q And on what date were you terminated?
7 A I terminated March 3rd, 1982.
- 8 MR. BISHOP: 1983.
9 MR. JONES: 1983.
10 THE WITNESS: , '.83. I'm sorry.
s 11 BY MR. POWER:
12 Q Do you have experience in the crafts?
13 A Yes.
l {f~')
N/ 14 Q Which ones specifically?
15 A Well, I worked at Todd Shipyards for about 12, 16 13 years. During that period of time I worked as an 17 electrician,, the machine shop in accordance with sheet 18 metal procedures, shipboard installation of electrical,
{
y 19 all electrical installations of cable, equipment.
t j 20 Q Am I correct in assuming then basically your j 21 crafts have been in the electrical field?
3 d 22 A Not necessarily.
2
[ 23 Q Ironworker also?
24 A And, well, no. I have not been an Ironworker.
25 Q Do you have any other expertise such as a welder A ms t
(
8 O;n i7 1 as an example?
G') ..
2 A I have had charge -- yes, I was in charge of .
3 the welding inspection and writing the welding procedures 4 according to some of the information acquired from our 5 engineering group. During that period of time, over my past history I've worked -- I have done a lot of welding, 6
7 not professional welding but Welding of my own, in the ship-8 yard during that time. I was in charge of the fabrication 9 of a lot of the installations that went into the ships, 10 inasnuch as drawing up the design for wireways, terminals, s -
11 you know, termination areas, things of that nature into the 12 equipment, also setting the equipment.
13 Q Can you give us an estimate of the total number (7N
'k J %s 14 of years you have in the crafts?
15
~
MR. JONES: Do you nean now where he was doing 16 hands on type functioning?
17 MR. POWER: A combination of both, yes, and g
l 18 this is again to get an evaluation when we have to present j 19 this information to our own Commission. They're very j 20 much interested in you know, whether or not you happen a
a 21 to be a degreed engineer or whether or not you have twenty d 22 years in the crafts. It gives them a better evaluation.
t 23 THE WITNESS: Well, the last nine years that
[
24 I worked for the Howard P. Foley Company at Diablo hs 25 has been over, mostly over the OA/QC program and prior to
((O)s-t 4
1 1
9 l n
(_) 1 that back to when I went into the Air Force in January 2
of 1952, from that time on it was working with the crafts.
3 O Basically then, from 1952 on except.for the last 4
eight years a generalization would be that you have 5 participated in the crafts?
6 A Yes.
7 Q Mr. Tennyson, could you tell us when you started 8 at Diablo Canyon, roughly what year was that?
9 A Febraury 4th, 1974.
10 BY MR. BISHOP: -
s -
11 Okay, so the plant was still under construction Q
12 at that time?
13 A Yes.
- ( .
)
- \~
~
,/ 14 0 Could you relate to us what types of pressure 15 you were subjected to as Quality Assurance Manager?
16 A Well, I was under quite a constant pressure 17 g because I seemed to have been told many many times that
! 18 I was an necessary evil --
j 19 0 Who told you this?
j 20 A This was by my supervision. I would say, Skip a
{ 21 Moses at the most.
f 22 MR. POWER: That's M-o-s-e-s?
I
- 23 THE WITNESS
- Yes.
24 MR. POWER: If you give a name, would you please 25 spell it? .
(
t
.t
10
(!
) 1 THE WITNESS: Oh, I'm sorrv.
2 MR. POWER: No,'no, that's all right. We didn't 3 explain it.
! 4 BY MR. BISHOP:
5 , O When he says, did he actually use those types 6 of words', necessary evil?
7 A Yes.
8 0 What was he intending by that?
9 A Really, that is sort of unknown for me to make 10 judgement on. . .
s 11 0 -Okay, I recognize that.
12 Did he -- was this in a kidding vein or was he
,-s 13 specifically inferring that he didn't really think your (i
'4 presence was necessary on the site?
15 fir . JONES: I think again you ought to ask him, 16 ask Virgil how he perceived the man's tone because
- 17 for him to say what Skip Moses thought is really speculative. )
j 18 MR. BISHOP: Certainly, fine.
i 19 BY MR. BISHOP:
j 20 Q Fine, can you tell us how you perceived that --
i 3 21 MR. JONES: Was he serious or was he kidding a
d 22 when he said that?
3 f 23 THE WITNESS: I did take it serious because 24 of the other things that had happened, I guess to bring 25 this on an.d taking into consideration the pressure that I t
4 I
l 1
I 11 e
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1 was under and not only myself but the whole QC department 2 and OA department.
3 MR. POWER: Would this recently occur -- say, 4 would you give us & feeling for the time frame when he, 5 when this --
6 THE WITNESS: No, I felt the pressure for just 7 about the whole period of time.
8 MR. BISHOP: But in reference to a pressure 9 you indicated that this has occurred in conversations with 10 Mr. Moses -- when was the last instance of such a conversa-s 11 tion where you obtained these feelings?
12 MR. JONES: Would it be better to start with --
13 I think it might help you 4f he started with the first C8- ,
14 instances you know, and then described what he experienced?
15 He's willing to do that.
16 PJ. . POWER: Hold it a minute. Off the record.
i 17 (Discussion off the record.)
j 18 MR. POWER: On the record.
i 19 BY MR. BISHOP:
a
- 20 Q Mr. Tennyson, could you tell us what pressures Ii 21 you felt and where they cane from?
E f 22 A Yes. My, ti.e pressures came from the various meetings in the Howard P. Foley Company's project manager's i! 23 24 office, Skip Moses and many times with Mr. Don Rockwell 25 of Pacific Gas and Electric Conpany who is now the Assistant
.A G'
I t
s
12
-3 i
'I I Project Manager for PG&E. Now, duri.n.g times when I was
- \s) 2 pressured for well, working not exactly as I considered to 3 be in accordance with procedures -- it was in Mr. Moses' 4
office many times that I was asked to or told to get those g/
5 red tag items, get the red tags off of the items in the field .
6 They did not want those items red tagged in the field.
7 Could you give us a specific example?
Q 8 A This was the biggest pressure came on this 9 structural steel reinforcement that we were building, 10 reinforcing and since we put so many new people into the s
11 field to do the inspections, we were pressured very-hard to 12 get these people indoctrinated and get them in the field
,. 13 and get the inspections going and the acceptance of all (X /(9 14 of the work that wa,s being done in the field and most 15 any time a red tag situation came up where we should have 16 written a red tag on a non-conformance. There was a lot of j 17 controversy over it, a lot of threats made by Mr. Moses.
j 18 Q Could you state what those threats consisted of?
g 19 A Well, in most cases I was told by Mr. Moses that j 20 if we didn't keep the red tags down a:id if we didn' t keep a
21 this job rolling, we were going to be more or less thrown f
f 22 off the job and another company would possibly take over.
I
- 23 Q Were there any cases where you or your staff did 24 act contrary to the procedures and not in fact follow the
,1 25 procedures.as required in the area of red tagging?
v
~_ , _ _ , _ _ . . , - - .m. , _ . ._ . . . . , _ _ . _ _ , , , , _._ _ _ __._._ ._ _ __ . . - ,
13 I A Well, there was the gentleman brought in -- I can't V) 1 2 think of his name.
3 MR. JONES: Just take it easy -- just relax, I'm 4 going to get some water here.
4 5 BY MR. BURDOIN:
6 Q Virgil, where was this structural steel work 7 being done? Was this the annulus area or was it the a fuel handling?
9 A Fuel handling was the biggest push, I think.
10 MR. BISHOP: Ypu.were going to think of an s
33 example of where the procedures were possibly violated?
12 THE WITNESS: I'm trying to think of the 13 gentleman's name that -- I'm drawing a blank here. The
-' (s
.s_) 14 gentleman's name -- Mr. Moses asked me to put a man in 15 since the job was getting so pressured and in so many areas 16 of responsibility and so many things to cover, we brought
- 17 in another gentleman as the inspector and I promoted him j 18 to a supervisor. He asked me to make him an assistant g 19 quality manager on the night shift. I can't tell you his c
j 20 name now but I will.
' a MR. JONES: What year was that?
l 3
21
- f 22 THE WITNESS
- That was prchably -- he hadn't 23 been there over 90 days, I don' t think.~ That would have i
24 still been in '82, the end of 1982. He was a gentleman 25 that was hi, red by the Cataract (ph) Engineering Corporation.
- UD I
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_m _, _ _ _ _ - . , , . , _ . _ , . . _ _ , , . , - -
14
!( \_/
[ )' 1 MR. JONES: Were they subqontractors to Foley?
2 THE WITNESS: As subcontracted to the Howard P.
3 Foley Company for qualified inspectors level.
I was told to pull some red tags, to get the 5
red tags down out of the field because the. field hands, 6
ironworkers had not been indoctrinated by their supervision 7
well enough to know the procedure that they could work 8
through a red tag providing there was a disposition on 9
the non-conformance report and had been issued to production to for that purpose of workihg through the -- you know, to s -
Il correct the situation. So in many cases there were red tags 12 hung in the field and they wanted the red tags down so
"'s 13 he instructed -- I wouldn't pull the red tags down and h(d 14 somehow he had instructed the night assistant manager to 15 gill them and I came back in te next day and found a stack 16 of red tags which had been pulled in violation of the procecu::e j " and stuck into the shelf in the quality manager's office.
18 5 They instructed ne and they told ne that the 19
[ field hands were very uneasy abcut working through red tags 20 f and they didn't understand the crocedure ,well enough to 21 know that they could work through a red tag so that's why f ,
f 22 they saw fit evidently to pull the red tags and deviate t
[ 23 from the procedure which was GCP-3.
24 BY MR. POWER:
25 0 What is a red tag? Would you generally explain O
os) t t
=
15 i
~N what a red tag is?
(h
\
i 2
A Well, our QCP-3 procedure reads that if a non-3 formance --
4 O Is that a Foley GC procedure?
5 A Yes.
6 O All right.
7 A It's the procedure for writing a non-conformance 3
and handling it. That non-conformance should be written 9
and at that time the red tag would go on the non-conforming 10 item. , ,
9; Q Is that writteh by'a OC inspector or an engineer?
A Written by our QA engineer. And the non-conformance 12 w uld be subnitt ed to PG&E either with a proposed disposition 13
~((, O, 34 made up by our engineering people.
15 0 Can you give me the audit trail from the time 16 that an engineer determines if he feels sonething should be
- 17 red tagged and he fills out the form, to whom does it go and how does it get to you to get to PG&E? Slowly.
'[. 18 y 39 A Okay, well, an inspector will go to the field
- 20 with his necessary procedures and his necessary forms to t 21 fill ut depending on te type of inspection he's going to make. If he finds a"non-conforming situation, he will h 22 e
! 23 write a red tag on the iter and document this on his paper-24 work and irmediately get a hold of the Foley Engineering grou?
25 for a number to put on the red tag and that in turn will be in s-e
16 l k.((~%) 1 lthenumberthatnon-conformancewillbeidentifiedunder, 2 that's depending on the specification nur.ber and then the 3 correllated number of the red tags that are non-conformances 4 that are issued in that particular specification.
5 Then, the non-conformance will go through its
'6 various review cycle and be submitted to PG&E with a 7 proposed disposition on it and PG&E at that time will either 8 deny that disposition or propose a disposition on their 9 own.
10 Q Okay, through this cycle then from the engineer 11 when he prepares his necessary paperwork, do you get this 12 on a day to day basis, you would then be advised of the red 13 tags being ' hun'g on such.and such: items? -Do you, in your
- ((~)
14 position as OA/QC manager?
15 A I know about them almost immediately, yes.
16 O Okay. Back to your conversation now, relative 17 to that, when would your immediate supervisor Moses be j 18 then brought into the picture that he would be knowledgeable g 19 of the red tags being hung and the possible disposition of
, G
- 20 such a situation?
a i ls 21 A Well, he wouldn't really be knowledgeable of it until the non-conformance had been officially typed up, l fs 22 j 23 given a number, reviewed by myself and signed and sent 24 into him for his signature and agreement on the non-conformance i 25 that was written.
i I
- t 4
- 17
) 3 Q Okay, so you had no problems obtaining your
~' '
2 NCR numbers and that, the normal --
3 A No, no.
4 Q Please correct me if I incorrectly summarize this 5
but, what you said is this new individual from the Cataract 6 Engineering Corporation was hired approximately at the end 7 of 1982 and then sometime later there was this discussion g about too many red tags being in the field and on a night g shift, he pulled the red tags and then you came in the follow-10 ing day shift and found a large nnnber of these tags in the quality assurance manager's office. Was it -- did you 33 tell us whether it was this individual who himself pulled 12 the tag or did he order the tags to be pulled? Do you know?
13 e'.O s
34 A I really don't know what the circumstances were.
15 I nly know that the red tags were in the office and I found 16 them at that time.
- 17 Q What was your action at that time?
18 A I questionned Rob Carter.
{
19 MR. JONES: That's the individual's name?
I j 20 THE WITNESS: Yes, MR. POWER: The night supervisor?
f 21 I Assistant Manager.
THE WITNESS: Night supervisor.
f 22 MR. BISHOP: Assistant QA Manager?
23 24 THE WITNESS: 00.
25 MR. BISHOP: QC manager. Okay.
sv L
18 i '. fs 1 BY MR. POWER:
(, --
2 Q Could you continue?
3 A To the best of my nemory rig't.t now, Mr. Moses, i
4 he told me that Mr. Moses had instructed hin to pull the 5 red tags. .
6 Q Without proper disposition?
7 A Well, I don't know if they had proper disposition 8 or not. I don't --
9 Q That wasn't part of the conversation that you 10 could recall?
~
11 A Now. %
12 BY MR. BISHOP:
13 Q When did this occur, do you know?
b a 14 A I'd say the third, probably second or third week id 15 in February.
16 BY MR. POWER:
- 17 Q Of this year?
18 A Yes.
g 19 Q You made a comment about, it is authorized to C
, j 20 work to br through a red tag? Could you explain that more 21 fully?
, =
f 22 MR. JONES: I don't think that's what he said.
3 MR. POWER: That's why I'm asking. Maybe I
[ 23 24 micunderstood what you said.
25 THE WITNESS: The only way you can work, what you
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\. (_) 1 might say through a red tag is to have a proper disposition 2 on a non-conformance report and a copy of this issued to 3 your production forces to work to that particular disposition 4 so that you may work the problem off but the red tag would 5 remain on the item, it should at all times, until the last 6 signature on the non-conformance report is there and the 7 corrective action is completed.
8 MR. POWER: Is completed?
9 THE WITNESS: Yes.
10 BY MR. BISHOP:. .
s 11 0 Could we continue then after Mr. Carter told you l 12 that Mr. Moses had instructed him to remove the tags --
13 where did the conversation go from there? You're shaking
.i I-~s1
' - 14 your head. Does that mean you don't recall or --
15 A I don't recall, I'm sorry.
16 0 What happened to the red tags that were removed? .
g 17 A I believe the red tags remained in the shelf in j 18 the QC nanager's office.
i 19 Q Did you take this issue up wit'.: any of the other j 20 Foley management, PG&E or Bechtel management on thd site?
2 l 21 A No. At that time, we were being pushed so hard d 22 and so fast and I-had so many bings to do that I could not 4
I cover it and keep ny inspection forces in the field and 4
- 23 24 going at that time. At that time, I was putting in 15, 25 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />,.sometimes a day, anywhere from 60 to 85 hours9.837963e-4 days <br />0.0236 hours <br />1.405423e-4 weeks <br />3.23425e-5 months <br /> a l(
(
20
. z (D , week.
- L) ..
2 0 What about your inspection staff ? Did they have 3 sir _ilar work hours?
4 A Yes, the inspection staff was working many many 5
vertime hours six days a week, some of them into the 6 seventh day.
7 Q Prior to this second or third week in February when this event occurred, were there any other instances 8
9 where, in your mind procedure sfiolations occurred and 10 Proper corrective actions,were not taken?
33 A I'm sorry, I cbuldi.' t recall any specifics on that right now.
12 MR. POWER: If you',re getting off the conversation 13 k(7-s ._-
34 with Carter, I'd like to ask one question.
MR. BISHOP: Go ahead.
15
.. OWER.
16
- 17 0 Was there anyone else present during that
,i 18 conversation?
19 A Not to my knowledge.
g t
BY MR. BISHOP:
j 20 0 What were your intentions as far as assuring f 21 i
J 22 that the non-conforming conditions which these red tags 2
g related to would be properly closed out now that the tags 23 24 had been removed?
25 A My full intention was, even though there had been Us.s -
. t
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21 t
((qj 1 a deviation from the procedure, that the non-conformance 2 would never be signed off until the actual work had been 3 completed.
4 Q Could you tell us what the significance is -
5 as far as the bottom line hardware quality is concerned 6 with the removal of these tags? Is there still a way to 7 go back and close out the non-conforming condition, another 8 record is it a fact that a red tag is removed creates some 9 other problems?
10 A Well, the non-conformance would not be closed 11 out until there was justifia'ble paperwork and inspecticn 12 forms signed off on. What I mean is approval, you know, 13 on the inspection forms so that the rework to the non--
1.
l 's 14 conformance could have possibly been completed and the 15 inspection forms filled out and approved and terc wouldn't 16 have really been a problem other than-the fact that they 17 were deviating from procedure by removing the red tags l 18 prior to the non-conformance being completed. Now, i
i 19 it would make it a little hard to get back to some of s
j 20 these situations for another person to identify a problem.
- 21 0 Shouldn't the -- well, perhaps you could tell 4 ;
d 22 me that the non-conformance report itself and deficiency j 23 report, does that contain an identification of where the 24 deficiency is lccated?
25 A Yes, it does.
- (~%
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. {
i
f 1 22 I
(~N i (sI Q Approximately how many of,those tags do you 2
think were removed that one night?
3 A That would be impossible for me to tell because 4
I didn't pick them up and count them.
O Ten, one hundred or a thousand?
- 6 A It looked to be a stack of maybe, 10, 15, to 7
the best of my knowledge.
8 Q Do you recall in general what types of deficiencies 9
were occurring at that point in time that these tags might 10 relate to? Were they weld quality or material in Il quertion? What types of problems were these tags, typically I relating to?
13 That assumes that he actually looked y- MR. JONES:
'/ 14 We don't know if you did or not.
them over.
15 THE WITi1ESS: They were involved in the welding, 16 in the proper placement in some cases of reinforcement 17 plates, wells that were questionable and to -- whether I 18 I they were severely undercut at times or n6t. I believe 19 i proper size wells were prob 3 ems we were running into which --
d 20
", BY MR. BISEOP: s
~
5 g
21 Q Are you aware of the dispensation of the non-J 22 j conformance reports thenselves, that is, was there ever 23 any indication that these were going to be tampered with 24 or discarded or inproperly handled?
25 A No indication to me at that time.
k t
~
23 R
/
t ) 1 0 Any indication since that time?
\_/ ,,
2 A No.
3 Q I want to skip to another subject just for a second 4 if I can. You mentioned earlier that there was a period.
5 of time when you were apparently hiring quality control 6 inspectors at a very rapid rate. .Could you discuss briefly 7 whether they were properly qualified and properly 8 indoctrinated before they were put out into the field to 9 work?
10 A Well, I have ,be,en told since the beginning of 11 my employment at Diablo'by v'arious Pacific Gas and Electric 12 people and by my own people at times, my own people in 13 the Howard P. Foley company that we were not under 10CFR50
. (...hsl 14 requirements. Foley, the Eouard P. Foley Company now, that 15 is, and that we did not have to level our inspectors to ANSI 4525 and ANSI 45223 on our auditing beat. We were not 16 held to that requirement strictly. During the period of j 17 18 time I have been out there we have endeavored always to i
19 try to indoctrinate our people in that direction but would j 20 never get a leveling standard through until just very
$ 21 recently here within the last few months which was 22 Deccaber 12th. There was a procedure written and distributed I that we were to level our oeople to ANSI 4526 which made
- 23
) 24 it very difficult because some of the new people we had 25 we could not -- we didn't have them quick -- we didn't have v
. t
- I la i
4 I them long enough to level ther to 26.
k[x /)
2 O When you say level them, you mean qualify them 3 in accordance with N4525?
4 A Yes.
5 Q Were they put to work?
6 A Yes, they were.
7 Q Does some individual certify'their readiness for a work?
9 A We have in our quality assurance departnent at 10 this tine Mr. Jim Thompsqn in charge of the quality assurance s
11 department. He is the quality assurance manager and he 12 has a section set up that is doing the leveling and 13 certification of our people.
(n/s_ 14 0 Are you stating that some people were certified 15 without proper qualification?
16 A That I could not attest to. I nean, I don't 17 know their background, their history so I couldn't say i 18 if they were or not. Only the time period that we had i
19 a 45 day indoctrination period in our procedure -- that's s
j 20 the only thing that I know of that we have deviated from c .
la 21 in qualifying the peope to 26.
f 22 Q I guess I don't understand what the 45 day 2
f 23 indoctrination period, how that relates to N4526.
24 A Well --
25 Q Was that 45 day a Foley required --
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s .
25 m
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I, 1 A This was a Howard P. Foley Company procedure now.
2 Q This is the December 12, 1982 procedure?
3 A Yes, yes.
4 BY MR. POWER:
5 0 And was this the period of time that they say 6 that it took to train an individual to be a level 1 or a 7 level 2 individual, is that what you're saying?
8 A No, that's not what I'm saying. Our procedure --
g I'm afraid you would have to read it to understand exactly 10 what it was to imply be,cause it wasn't written -- I don't 1
11 think totally to ANSI 4$26. 'The procedure was written due 12 to an audit that was perforr.ed by Pacific Gas and Electric's 13 OA Department, Mr. Dick Twitty.
r a (x/ 14 BY MR. BISHOP:
15 Q Prior to December, 1982, you made reference to 16 the fact that the Plant was not under 10CFR50, Appendix B.
17 Did you employ inspectors who were not competent in the j 18 inspection of the activities they were responsible for?
- g 19 MR. JONES
- Did he personally employ such people?
BY MR. BISHOP:
l 20
.f! 21 Q Did Howard P. Foley at the Diablo Canyon site I
f 22 employ inspectors who were not qualified?
E 23 MR. JONES: If you know.
24 THE WITNESS: I really wouldn't answer that one 25 because I, hate to judge another man's qualifications. I ef i
- t 1
26
<~
-(% )l 1 l don't think I can. ..
2 BY MR. BISHOP:
3 Q What about the instance that the period of time 4 when you were both QA an9. quality control manager?
5 A Of the people that we hired, we felt were under 6 the conditions were working and the restrictions that we 7 had to our procedures, we felt that we could indoctrinate a then well enough to follow 1 procedure which is really all 9 they were required to do at that time, was follow our pro-10 cedure and document their inspection to a procedure and s
11 to a specific inspection form which was part of the 12 procedure.
-, 13 Q Did you meet your contract requirements in-that area?
15 A Contracts requirements was never really discussed 16 with me. Mr. Moses was the only one that took care of 17 the contract requirements.
g j 18 Q Did you personally ever perform any inspection 3 19 of the hardware in the field at Diablo Canyon?
~ '
y 70 A Yes, I have.
i
$ 21 Q Have you done any inspection since the December E
d 22 time freme?
I MR. JONES: That's lc82?
[ 23 24 BY MR. BISHOP:
25 0 1982?
.t r ~g . - - - - - - - . - - , __ - . , - . ~ - - - - _ - - - -
27
- l A
{v) 1 No.
2 0 What is your opinion about the quality of the 3 workmanship in areas that are under H.P. Foley responsibility ?
4 MR. JONES: That's a broad question. Would it' 5 be fair for him to answer --
6 MR. BISHOP: Perhaps I should rephrase it --
7 MR. JONES; There are different areas of 8 workmanship.
9 REPORTER: Excuse me. :Could you speak one at 10 a time, please? . .
s -
11 MR. JONES: Yes. There are different areas of
^
12 workmanship and maybe it would be -- I don' t know if it's 13 appropriate, Mr. Tennyson for you to answer different
((3 )
\ \
s- t' answers with regard to different areas of workmanship --
! 15 why don't you break it down if you need to answer it 16 that way.
,g 17 MR. BISHOP: Perhaps it would be easier if I
,j 18 rephrased my question.
!i 19 BY MR. BISHOP:
lj 20 Q Are there any instances you are aware of where
!i ii 21 the workmanship does not conform to requirements?
'a f 22 A Well, I would have to say that due to this big
[ 23 push hat we had --
l 24 O Starting when?
1 l 25 A , Starting the first of the year on the modifications ,
l
\
l
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l l
L_
28 !
(3
\ j/ 1 there were so many people, nev people hired and so much 2 confusion in trying to indoctrinate all of them, both the 3 crafts to get out and follow the instructions and the diagramt 4 and procedures they had to weld to and in certifying the 5 welders, we also, in putting new inspectors in the field to inspect their work, there was so much confusion due to 6
7 design change and our package program putting it together 8 which was a package program which was supposed to instruct 9 the field hands to do a speficic installation the same 10 as the inspectors would.be required to inspect it, due to s -
11 all of this there was so much confusion that there were 12 a lot of mistakes and'this is what brought the pressure 13 down on the OC Department because they were noting these J ]ggl
\# 't mistakes as they came up and it was slowing the project 15 down.
16 BY MR. POWER:
17 Q In reference to that specific point, you say g
{. 18 there were many mistakes -- were these identified and i
19 corrected at that time?
e j 20 A To the best of my knowledge, they were.
( i
$ 21 Q You're not aware of any instances where there E
$ 22 were not problems or an area that was not corrected?
3
[ 23 A No, I don't think there was any intent to 24 not repair anything that had been installed, non-conforming.
25 (Pause)
O
, \L )
t
. 1
. l 29 1
[3 1 BY MR. SISHOP: i
\~ l' .. 1 I
2 Q In addition to the red tag incident which you 3 described, you kind of inferred that there were other 4 instances where procedures may not have been complied with.
5 Can you identify any other instances?
6 (Pause) 7 MR. JONES: Again I'm not sure that that's what 8 he said.
9 MR. BISHOP: Okay.
10 BY MR. BISHOP,: , ,
11 Q Was that the only " instance then?
12 A I think that was the most, the one that was 13 pressed on my the hardest was the m6difications.
' N_,/ 14 Q You indicated that there were threats -- if 15 you can't keep the job rolling and that these threats 16 came fror Mr. Moses, were there any other individuals who .
- 17 made what you call threats?
j 18 A No, not to my knowledge, no.
i 19 BY MR. POWER:
f 20 Q In reference to those comments that were possibly 21 made by Mr. Moses, was anyone else present?
$ 22 A I believe Mr. Jim Thompson had just the same i I
! 23 threat that I've had.
{ 24 Q Were you specific.tly knowledgeable or present 25 when that , type of conversation occurred or is this an Yv
. (
l l- - .. .
30 E( 1 assumption? , ,
2 A Yes, Jin Thonpson has discussed it with me 3 and I really feel assured in saying that Jim Thompson has 4 been available when threats were mede concerning our jobs.
5 Q Directed towards you?
6 A Yes.
7 Q Okay, have you been present when a threat has 8 been directed towards him?
9 A No, not to --
to O To the best of.your recollection?
s -
11 A Not to the best of my knowledge.
12 0 Are there any other individuals in a supervisory,
.,.,- 13 non-supervisory position that could have possibly received it ( ') '- 14 threats in a similar matter from Mr. Moses?
15 MR. JONES: You can answer that. Answer of your i
16 own knowledge.
- 17 HR. POWER: Yes, of your own knowledge.
j 18 THE WITNESS: I had an assistart quality manager l
19 on days, Mr. Rick Roam, R-o-a-n who was threatened this j 20 same day that I was terminated and Mr. Moses told him a
a il 21 that he was to fire a certain amount of or a certain number d 22 of inspectors in the field who were classified as rod
, t
_! 23 oven attendants and Mr. Roam refused to fire them so l
24 Mr. Moses threatened him with termination at that time.
25 /// ,
'(. ,
.t e v '- w =<e--- -- -
3
- ,,n , , , _ , , _ , _ , _
. 31 BY MR. POWER:
.[v] 3 2 0 How did you become knouledgeable of this3 instance?
3 I'm interested in your direct knowledge or hearsay ' type.
4 That's fine.
5 A Through Mr. Roam, directly to me.
6 0 Were you present during this conversation?
7 A No.
0 This_is. hearsay you received?
8 9
A This was between Mr. Moses and Mr. Roam and there was another gentle: nan in the room but I do not know 10
\
hi"*
11 g 0 Any idea who the other --
A I believe he was a Howard P. Foley employee, 13
' . (O)
, y seened to be a new person in the company who was sitting in with Mr. Moses.
15 BY MR. BISHOP:
16
- 17 Q Was Mr. Roam fired?
A Yes.
I l 18 0 Do you know what the reported statement was for j 19 his firing? I assume they make a document out, a card or 20 j [ 21 something 3ike that when you're fired or terminated?
l5 No, I couldn't ansrer that.
A f 22 Q We're aware of a ro oven attendant issue that i 23 24 came up sometime in early March or late February dealing 25 with the site evacuation related to the weather and the l(-[Sv]
\
! 32 i
((\d ) 1 f act that welders would turn in their rods and I guess what 2 was reported to us, anyway was that the rod attendants 3 had already evacuated. Was this the issue related to 4- these rod oven attendants?
[5 A ~Yes, it was.
S6 0 Were you involved in any discussions related to 7 'that incident,Eand if so, could you summarize them for us?
s 8 MR.~ JONES: Now you're asking about discussions 9 after the< fact of the incident itself?
10 MR. BISHOP: ,Ri,ght.
11 THE WITNESS: 'Ye s . ' On December the 2nd, or 12 I'm sorry, March 2nd,1983, I was told about 10:45 by
- 13 Mr. Moses who came back to my office in a big hurry and told
- (.
' ' f,%s_ j! ' 14 me that they were going to evacuate all the people from
. 15 the plant due to weather conditions and for all the people 16 that I had who'came in at 6 o' clock, he wanted them out 17 at 11:15, out of the plant. For all the people who came j -
18 in at 6:30, we wanted them out at 11: 45. At that time, y 19 which didn't leave ne much time to evacuate the people out h 20 of there and the hurry for it, I assume was the fact that 2r there were busses waiting in the parking lot to take the i !
f 22 people back to the automobiles or to their point of origin.
I didn't ask any question, I just -- I asked.him -- do
[ 23 24 - you want everybody evacuated? Yes, he said, Mr. Moses.
a 25 said, evervbody is to be evacuated and I don't want any A
(V t
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- - - - - - - - - - - , , , . _ , ,-_,-----,y - - - ,
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e.
4/ l '
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33
( stragglers. .So at that time, I made a phone call out to
) i 2
RickRoamwhowan'myAssistantQualktyAssuranceor 3
Quality Control Manager, told him of the evacuation plan. j 1
4 I also had a number of people, inspectors and my secretary and electrical inspection type people in tus of fice that 5
more or less heard the statement that Mr. Moses made.
I 6
7 started to go out -- I have a big -- had a double wide 8
a e out alongside of tb.e o0_' ice building which housed the civil and mechanical people and I had to get out to 9
10 th,at trailer to let them know tha't, possibly, what the evacuation was. There 9as a' lot of confusion at that time, y
g a lot of people going in all directions, wanting to know what was happening so when I got to the trailer, Mr. Roam
( ) was on the telephone. Someone had called him and asked him what the deal was, that they were pulling out the 5
16 security people which was a sign to the rod oven attendants.
, 37 Now, the security people were handled by another supervisor, I
IS not myself and the reason for the security people wede
.i
. 39 to escourt my rod oven attendants who were in secured.
areas that could not, that had not been through their 70
. security clearance yet, so they had to have an escourt l 21 i
g with them. Evidently, someone had given the esecurts j
notification that they were to pull out of Unit 1 at 23 a certain time which I do not know what time they told them, 24 25 that the escourts were leaving and ny people were on the i
f i TV
.- . t i . - .
34 !
((t3) 1 ovens -- the rod attendants were on the ovens and didn't ,
2 know what to do. They had made a phone call into Mr. Roam, 3 so Mr. Roam was on the phone at that time, really not 4 knowing what to tell them and when they told him that 5 they were -- the escourts were being pulled out, he e::plained 6 it to me and I told him, all right, pull the rod oven 7 attendants out, lock up the ovens and pull the rod oven 8 attendants out. Do not breach the security, because I 9 knew that the next morning, they had already told me that 10 there would be no night shift welders on, there would be s
11 no welders in the plant, there's no way anybody can be 12 doing welding with a rod that was laying on the tables to 13 be turned in and the next morning, very early we could pick
,7 S O-14 up the rods, check our paperwork out and if all the rods 15 checked out and everything, then we would know that we 16 had covered the situation and write a non-conformance
. 17 against ourselves that Me had deviated from procedure I
- 18 and possibly you know, clear it up that way. So this y 19 was done. The people were pulled out of the field and a
- 20 the next morning, after we secured the area, cleared the a
a
!a 21 area on March 3rd, 1983, we came in. I came in about --
f 22 I was late for work myself -- about 8 o' clock I guess s
G ,E 23 and Mr. Moses had left word that he uanted me to come 24 into the office and talk to him, not knowing yet that he 25 had already talked to Mr. Roam.
U('h.
t
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1 -
35 r\ Prior to him calling for me, he had already called in
( ) 2 Mr. Roam to have him explain the situation, what had happene d 3
the day before, why were the rod ovens left unattended, 4
what they had -- what Mr. Roam had done was told the rod 5
oven attendants to leave a note on the rod evens, lock them 6
up and tell the people to leave their rod cans which were 7
numbered by the rod ovens so they could be picked up the 8 next morning.
9 Mr. Moses had called in Mr. Roam and wanted him to 10 fire all the rod oven attendants that were on the, in 11 Unit 1 and Mr. Roan ref'q, sed'due to the orders we had the 12 prior day.
And that's about all I have to say.
13 BY MR. BISHOP:
A 14 Q And that's when Mr. Roam was terminated?
d is A Yes 16 0 I guess, for refusing to do that. Did anyone, 17 either yourself or Mr.
Roam inform Mr. Moses that if the
.! 18 rod oven attendants evacuated the site that procedures g 19 a
woul6 he violated and the fact that rods wouldn't be 20 properly taken in an6. accounted for?
f.
g 21 A Not to my knowledge.
- Him being the project J 22 manager, I would have thought he'd known that himself.
23 Se does sign all the procer?ures.
04 Q I see.
What Vas the triggering event in your
! 25 termination?
\
l i L e
1 MR. JOSES:
=
2fUhydon'tyouj Again, 36 31 1 that don 't you ust ask cal?.s for i
4I ask him about him about the ev a judgement.
\_/) he vill the ents of tell v ou eventu the 5' .sy 2 what he .
of 'he 3rd of r BY 6 MR. BISHOP: experienced. March and O
7 Okay.
Could A you tell us a about about, Mr. Moon the third of March I was the 3rd of March?
9 ses ' office where in there. There about 8, betw called into the 10 1 was een 8 and office don 't know u of who he was. another gentleman in 8:30, some-the Howard P. s the 12 Mu t have been a new office.
13 me what had happenedFoley he Company Mr. Moses employee explained th,at.the explained 14 to ne that the s - he was to very upset and 15 unattended and it wa rod ov ever happened s one of the worst ens had been left 16 to requir to us
() 1:
, what could be done e at Diablo Canyo my discharge.
I explained n.
things that had And, it was going 16 evacuate the day b and what we had in to him thoroughly ,
19 be r efore, nind when
\
w itten that a we did 20 v ery very easily, non-conformance j quickly and the paperwork co l could 21 knowing that u d he PG&E there was could have accepted cleared up 22 no the field and no 23 unauthorized ork wunauthorized e
o in the w ll r dsituati
- i unauthorized w fr e
- o. ll r d had been done ession with any 25 Q
on him. This didn 't seem o maket any How long did this conversation last i
, or your !
!).--w b
.t
. 37
/~' I discussion with Mr. Moses?
2 A Probably fifteen minutes. .
3 Q What did you do then?
4 A I asked him if he wanted me to leave the site -
5 right then or did he want me to go b ack and get some 6 people lined out with the work that we had outstanding, 7 our paperwork. And he said he'd appreciate it if I'd 8 go back and fill somebody in, fill them in on the paperwork 9 and try to keep the job rolling which Mr. Roam had done 10 all the morning, too, und,er realiy the same circumstances.
11 I did go back to my offfee, 'did sign a number of documents, 12 work documents that required my signature to process on 13 through inbetween cleaning out my desk and that type of l(T 14 thing.
i 15 MR. JONES: Have you, in summarizing the 16 conversation with Mr. Moses that morning, have you omitted
.- 17 some of the details and some of the more emotional comments
[. 18 Mr. Moses made in order to be concise this afternoon?
lg 19 THE WITNESS: I could have. Is there any way
,j -
20 we could maybe stop and maybe --
1-
,[ 21 MR. POWER: Yes, certainly, we can go off the 3
record.
ldt 22 j 23 (Whereupon, a brief recess was taken.)
24 ///
! 25 /// .
1 \
t t
t l :
l Lm
1 !
35
( 1 MR. POWER- O*: the record.
2 BY MR. BISHOP: .
3 Q Mr. Tennyson, I understand something your -- you 4 have recollected some other aspects of the conversation with
~ ~
5 Mr. Moses on the 3rd of March. Could you inform us of..what.
6 that was?
7 A Yes. During the period of time he was explaining 8 to me the situation that had happened the prior day of the 9 evacuation and the weld rod attendants leaving their stations .
10 He told me that it was.a. terrible thing, and along with "This s -
11 is the worst thing that's ever happened to us on the site 12 here." And he said, "I'm just going to have to let you go."
13 He said, "PG&E is pushing me and there's really nothing I i
'( d[_ 14 can do about it."
15 Q Did you have any conversations with PG&E . . .
16 A No, I had --
j 17 0 . . . concerning the situation?
j 18 A -- no conversations. I -- all I merely stated back j 19 to him, "Well, you do what you have to do, or whatever."
20 0 Was there anything else on that converstaion that
'g 21 you . . .
lf 22 A As I got up and left the room, I thought of how I i
0 23 would be terminated and future. jobs and so on. I went back
- [
I 24 to his office and asked him -- excuse me -- what would'it l
25 show, what would be shown on my termination slip. And I said .,
t k(_/
. .t t
l me
2' 33 C-s,,) 1 "Well, could you -- do you want to make it fired, terminated, 2 for what reason, or . . . Do you want to put on ' voluntary 3 quit'? How do you want to handle it?" And he said, Well, 4 I'll get back to you a little later on."
5 Q And did he get back to you?
6 A Yes, later, must have been around -- later in the 7 morning. Must have been around noon or something. I don't 8 recall the exact time. He did come back to my office.
9 Came walking into my office and Mr. Rick Roan was sitting on to the other side of the room, behind the door. And Mr. Moses s
11 did come in, leaned over and told me, "On -- I put ' voluntary 12 quit' on your termination form. It'll make it easier for you 13 to draw unemployment." And I said, "That's fine, Skip.
,.7 s
' \"")
u Whatever you feel is right." At that time, Mr. Roan asked 15 him, "Does that same thing apply to mine," or something to 16 that effect. And Mr. Moses was surprised, evidently, to see
- 17 him there, and he said, "Oh, yes. Yes."
l 18 O Did he in fact put that reason down on your'termina-h 19 tion slip?
i .'O A Yes.
[ 21 BY MR. POWER:
f 22 O So officially then, neither you or Roan were termi-t l 23 nated or fired?
24 MR. JONES: Well, that --
25 MR. POWER: Involuntarily.
k
(
, -- - --- , , , - - , , - , ,e -
, ,- - ---- --- a --n--,-----e-- - .- ,
3 40
.N MR. JONES:
((J 1 2
That question -- that question implies that Virgil understands what " official" means. .
3 MR. POWER: By the record, yes. I'm interested in 4 the manner in which the -- the firm terminated your employ-5 ment. By what you have just related to me, the assumption 6 that I would make, based upon that, is that by the comments 7 made and the way you received it, that you voluntarily termi-8 nated your employment on your own volition.
9 MR. JONES: I am going to instruct you not to answer 10 that question, Virgil., My understanding is that that cer-11 tainly wasn't your intent, and what -- what Mr. Power would 12 infer from that is really not material.
13 BY MR. BISHOP:
/ 14 Q Okay. Was there any other aspects of the conversa-15 tions on the 3rd of March that you'd like to inform us abouti 16 A Nothing other than I fulfilled my obligations as j 17 quality manager up until about two or two-thirty before j 18 departing from -the company.
j 19 0 Who -- did you turn your work activities over to any 4 30 one individual when you left?
- A M A No, I talked to numerous supervisors who came in h
a f 22 very much surprised that I was leaving. Distributed a few t
j 23 papers which I had on my desk,.and the job requirements and 24 so on. There was really no one to turn it over to at that 25 time. The,re was no one to take my place. I might add, I was s
t 4
. - = - .
4 l 41 1 the only Level 3 that they had available, at that time.
2 Q That's quality control Level 3, ANSI N45? .
3 A 26, yes.
4 Q 26? Okay. Were there any other issues relatin'g to 5 this weld rod control and site evacuation that are worth 6 mentioning? .
7 A No, not -- not to my knowledge, no.
8 MR. BISHOP: Do you have any questions?
9 MR. POWER: Yes.
10 BY MR. POWER:, , ,
11 O In reference to the evacuation, are you aware of 12 any individual that would have violated a possible security 13 regulation by not remaining with a security guard or escort
'( \sO/ u at the time of the evacuation?
15 MR. JONES: I'm not sure I understand the question.
16 MR. POWER: Did he have any -- anybody along the
. 17 line, to include the oven attendants, that were in a position 18 in a so-called security area without a security guard that
[s g 19 you have direct knowledge of?
j 20 THE WITNESS: No.
, a l 21 BY MR. POWER:
a f 22 Q Well, based upon the conversation you related, it t
l 23 was my opinion that they basically, as they were being with-24 drawn, they went with the security guards at the time, so 25 they did not violate another -- another procedure, in this
{
i
r e i
5 ; -1 'd L- ) 1 case a security procedure, to the best of your knowledge?
2 A Yes.
3 Q Good.
4 MR. JONES: But you were asking him whether he was 5 aware of any people who had to be accompanied by the escorts, 6 is that correct?
7 MR. POWER: Yes, right.
8 MR. JONES: Were you aware that there were people 9 who had to be accompanied by the escorts?
10 THE WITNESS: .Oh,.very definitely.
s 11 MR. POWER: Yes --
12 THE WITNESS: Yes.
13 MR. POWER: Yes, that I understood before.
( '-
- MR. JONES: Okay.
15 MR. POWER: Right. I just wanted to make sure that 16 someone wasn't left behind.
- 17 MR. BISHOP: Yes.
l 18 MR. JONES: I see, h 19 MR. POWER: If you call the guards and you're ...
[
20 MR. JONES: Thank you. I misunderstood your ques-i 21 tion.
i d 22 MR. POWER: Okay.
I 23 MR. JONES: So you were asking whether there was 24 somebody left behind and not whether there was somebody who 25 was subject to that requirement.
k t
4
6 9
( 1 MR. POWER: Yes. Yes. ,,
2 THE WITNESS: I might add that before I was termi-3 nated -- or before I left the site that very morning, that 4 there was a non-conformance.
5 MR. JONES: March 3rd?
6 THE WITNESS: March 3rd. A non-conformance had 7 been written. And the paperwork had been picked up.in the 8 morning of March 3rd very early, at starting of the shift at 9 six o' clock.
10 BY MR. BISHOP: .
s 11 0 This is all the paperwork associated with the rod?
12 A With the rod ovens.
13 0 Withdrawl slips?
( *: A Yes.
15 0 And control --
16 A And the rod withdrawl slips and so on, yes. And 17 all rod was. checked out and found to be available at the
[. 18 ovens. There were no rod stubs left over. There were no h 19 rod -- all rods were destroyed that were left in the can.
- ?? So we took it upon ourselves to get that situation well in f: 21 hand the first thing in the morning. That was the orders.
s 22 I have a -- a supervisor over the weld rod attendants who l 23 was very knowledgeable of procedures, and he took it upon 24 himself to -- to fulfill all his obligations without being 25 pushed, and it was a Mr. Michael Cox. And he's very much
. t
.11 ys 1 aware of this whole situation as to how it happened.
2 Q Okay. Anything else related to the rod control 3
issue?
4 A Well, yes. I'm a little confused as to why this 5
situation was referred to as the worst thing that ever 6
happened to us on site, when a prior situation had arisen 7
where PG&E had instructed the Howard P. Foley Company to 8
take uncontrolled rod from an uncontrolled area and disperse 9
it to the field and allow them in a se -- Unit one secured to area without any rod control methods or rod control proce-11 dures being taken into effect.
12 Q Could you describe this incident?
13 A I can't give you the dates.
%.(ejg 14 O Approximate, to the best of your knowledge will do.
15 A I would say it was in possibly January.
16 0 1983?
j 17 A '83. Or just prior. I came to work one morning.
'j 18 I was called' into the office that -- and told that the NRC j 19 had been out in the field and picked up numerous weld rods j 20 a and found cans of weld rods which were uncontrolled, some
! 21 a on the floor, some in boxes; a rod oven that was plugged
!f 22 into a wall -- a wall socket, I might add.
t And I was told t
23 that I was to go to a meeting with Mr. Rick Ensler who was N
the project manager of PG&E, and explain to him that we were 25 writing up, I believe, a non-conformance on this situation,
(
k.)
. l
E' 15 i
' nT l 1 l and explain to Mr. Ensler exactly what we intended to do to
- 1) __
2 correct this situation.
3 I did, in fact, go up to Mr. Ensler's office with 4 the assistant project manager Mr. Ray Lathrom.
5 MR. JONES: Who's the other person?
6 THE WITNESS: In attendance with this meeting was 7 Mr. Don Rockwell, Mr. Rick Ensler, Mr. Ray Lathrom, myself, 8 Mr. Glen Brown, who is a night assistant quality mana,-- or 9 night assistant project manager for the Howard P. Foley 10 company now. And explained to Mr. Ensler that we intended s
11 to do away with the uncontrolled rod situation we had within 12 the Howard P. Foley Company and exactly how we intended to, 13 to handle these uncontrolled rods which were supposed to have r
's M been a construction aid only and not to be used on any Class 15 One situation. I did in fact explain this to Mr. Ensler and 16 he did agree that it sounded like a good idea.
17 I then attended the -- along with these same people, g
j 18 I did attend the NRC exit audit on the findings of this j 19 particular situation. And to the best of my knowledge, the 3 20 outcome of the meeting was that the findings would be evalu-e l 21 ated against the procedural requirements, and at that time l E d 22 it would be decided as to whether there was a violation or 2
, [ 23 a citation situation in -- in order or not. What happened 24 after that, I do not know.
l
- 25 // ,
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9 lb
- l. . /^N
) 1 BY MR. BISHOP:
-( O -
2 O You mentioned that this -- something about this rod 3 being used for construction support activities. I don't 4 recall the exact words -- ,
5 A Construction aid.
6 Q Construction aid. Does that mean it was not rod ,
7 that was going to be used in a permanently-installed system, 8 structure or component?
9 A That's true. It was uncontrolled to the point of 10 where a -- well, a nonvgualified welder could take it and s
11 weld up a plowshare or a back end of a truck or things of 12 that nature.
13 Q Was that in fact --
(f'
~N A In a shop.
15 Q Was that in fact where this rod was used?
16 A Yes. It was in a civil warehouse building, uncon-17 trolled, where they could go into the oven, which was not
! 18 hooked up, by the way. It was just uncontrolled rod that h 19 was to be used at that point only, not to be used in the j 20 field or to be carried in the field.
21 0 To your knowledge, were there any instances where a
f 22 uncontrolled rod was used on a safety-related component, I 23 structure or system at Diablo Canyon?
{
24 A None to my knowledge that was never recorded.
25 0 And those that were recorded, were they properly
%p) v i . t
10 !
17
<x U 1 dispensed?
2 A Yes. I am sure that there -- you would find that 3 there was non-conformances written on any situation like thai..
4 Q Following the -- your return from the break, was 5 you -- I guess Mr. Jones mentioned that you recalled another 6 incident involving welding over a weekend and non-controlled 7 rod. Could you describe that event to us?
8 A That was the one I just . ..
9 O Oh, okay.
10 A . . . described.
s -
11 Q Okay. So that rod --
12 A Of . . .
,r' 13 0 -- involved what -- what you referred to as " con-lN struction support"?
15 MR. POWER: Aid --
16 THE WITNESS: Construction aid.
- 17 MR. POWER: Aid.
[3 18 MR. BISHOP: Construction aid.
i 19 THE WITNESS: I wasn't -- but before I went to this c
j 20 meeting, I was instructed by Mr. Moses that you don't point I a l 21 the finger at Mr. Rockwell of PG&E, let the Foley organiza-f 22 tion take the brunt of this.
'j 23 BY MR. BISHOP:
24 Q I see. Now this was in reference to the NRC find-i l
25 ings that.some filler material was not being properly t La) h l
. .t
, - - + - - - - -
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11 IS
( 1 controlled? ,,
2 A Yes.
3 MR. BISHOP: Any other comments or --
4 MR. POWER: Not with this.--
5 MR. BISHOP: -- questions you have in reference to --
6 MR. POWER: You have something?
7 MR. BISHOP: -- weld-rod filler material control?
8 MR. BURDOIN: Well, I'm acquainted with this inci-9 dent because it occurred on that inspection, I think, that 10 Gonzalo and I made -- . .
s j 11 THE WITNESS: Yes.
12 MR. BURDOIN: -- over there, and I believe that was 13 around the 17th of January, that week of the 17th, I believe.
(,Q(_j 14 MR. POWER: All's satisfactory, taken care of?
15 MR. BURDOIN: Yes, I believe this issue has been 16 resolved. Exactly the resolution, I couldn't tell you the 17 details without going back to my notes. It's -- it's written g
l 18 in the report that's part of the . . .
h 19 MR. BISHOP: The inspection report?
j 20 MR. BURDOIN: Yes, it's in the inspection report.
i !: 21 MR. POWER: Right.
d 22 MR. BISHOP: Okay. I think, Gene, you had some 2
,Y 23 further questions about the red tag --
24 MR. POWER: Yes.
25 MR. BISHOP: -- situation that we talked about I . /~'i l ~\-) .
l I
o 4
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+
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{ earlier. ..
2 BY MR. POWER:
3 Q And I don't mean to infer something that you haven't 4 said. I'm interested in the normal disposition of the red 5 tags. I believe you indicated you found them in the offices 6 one morning when you came to work, in reference to several, 7 several red tags.
8 A Yes.
9 0 All right. What would have been the normal disposi-a 10 tion? What directed, do you recall, your attention to the s
11 red tags in -- in the office that, that time?
12 A I couldn't tell you that. Through general conversa-
.f3 13 tion . . . or by word of mouth, by possibly one of my super-(!\# \
There were so many at that time and so many questior.s
- 'l visors.
~
i I 15 regarding the work in the field, and such a big push on get-16 ting the work done and getting the red tags down. And . . .
j 17 0 Do you normally have red tags -- did you hormally 18 have red tags in your office?
I 19 A No, never.
, g 20 0 What would be the normal disposition from the QC, j 21 either QC or QC -- QE, whatever you call 'em, the individual a
f" 22 inspector, what is the disposition of a red tag when they
! ; 23 finally take care of the NCR?
24 A Well, going through the sequence, you would iden'.ify 25 a non-conforming situation -in the field; you'd write the ntn--
-s O')
. t t
l l
\ . . . . -. - - . . .-. --
17 i dO gs s
( ,) 1 conformance up on it, identifying it with a number.
2 O Yes, just how it's --
3 A And --
4 Q -- disposition. We went through that previously.
5 A Yes.
6 Q You don't have to repeat that.
7 A Okay. And then you would have a corrective action 8 portion, and that corrective action would have to be rein-9 spected in the field in accordance with procedures and so on, 10 and approved documentation.on it accepted, acceptable docu-s 11 mentation on it to justify the corrective action. And at 12 that time the -- it would be signed off by the project man-13 ager of the Howard P. Foley Company and by the project -- or, l
l (s) 14 by PG&E, which --
15 Q Okay. Before, before it gets to that point, how 16 does it get from the QC inspector up to the project manager g
17 and H.P. Foley?
l 18 A Well, the corrective action is typed in by the h 19 people who do co the work, I mean, as to what was done to l
l j 20 correct --
a t
a l 21 Q I mean, I mean --
d 22 A -- the situation.
i I
[ 23 Q I mean a little more -- I mean a little lower than 24 that. In reference to the, the actual performance by'a QC 25 inspector.as he inspects it, it's all correct. What happens 0
l (l\m /
l t
l h
l
.14 31
!.( / ~.
- 1 to the red tag? Who pulls it off the piece of equipment?
2 A The inspector doesn't pull the red tag off until 3 the last signature is on non-conformance and the com -- the 4 corrective action completed is acceptable, and signed off.
5 At that time, the red tag comes off.
6 Q Okay. What happens to the red tag, the physical 7 disposition --
8 A The red tag --
9 Q -- of the red tag?
10 A -- is destroyed, t s -
11 Q Destroyed, by --
12 A Yes.
13 0 -- that QC inspector?
'" ~~
A Yes.
15 0 Okay. It's an unusual situation where you would 16 have some type of red tags that were not blank that would g
17 end up in your office?
- 18 A Yes.
j .
j 19 0 Okay.
- j 20 MR. JONES: I think he said -- didn't he say before Ii 21 the break that that was the only time it ever happened?
i!s d 22 MR. POWER: Yes, I believe --
j 23 THE WITNESS: Yes.
24 MR. POWER: -- that is true, yes, Right.
25 MR. JONES: Meets my definition of unusual.
h
! i
. (
t 1
~ '
'15 32 f--( ( ~)' 1 MR. POWER: Now -- and I agree.
2 BY MR. POWER:
3 Q You don't recall specifically, though, what directed 4 your attention to those red tags. It could have been a' con-5 versation or . . .
6 A Well, I think it was the fact that there --
7 Q They were there --
8 A -- was so much harassment over -- over the fact that 9 there were red tags in the field --
10 Q Okay. . .
s 11 A -- and they wanted them down, PG&E --
12 O Did you physically look at --
.- 13 A -- and Howard P. Foley.
( "_
14 0 -- these red tags?
15 A Pardon me?
16 Q Did you physically read these red tags?
- 17 A No, I did not.
[. 18 0 Do you know whether or not they were completed red h 19 tags, had they already gotten an NCR number and some type of c
j .
20 disquali -- disqualifying item indicated on these red tags?
l s
21 A They were red tags that were hanging in the field.
f 22 And --
t 23 0 How do you know they were red tags that were hanginc 24 in the field?
25 A I was told that.
/~~
's W
16' 5'J
. /~N i ( ,) 1 Q And who told --
2 A I --
i 3 Q -- you that they were --
4 A Mr. Bob Carter. I asked him if he pulled these red 5 tags and he said yes.
6 Q Okay. ,
7 A And it was by Mr. Moses' r2 quest --
8 Q All right.
9 A -- that he pulled them. He was --
10 Q Now, to the best of --
s 11 A -- called in the office and told to pull them.
12 O Okay. And to the best of your knowledge, these
-s 13 would have been -- everything up till that point in time
' ' \'- 14 then, best of your knowledge, was procedurally correct.--
15 they would have had an NCR number, they would have been 16 properly completed -- not the job. There's no reason to 17 question anything else, -- up till the time that Carter said j 18 he was f.irected to remove them from some type of equipment i
19 or what.ever.
C j 20 A That's true. We --
a la 21 Q Okay. And that situation, do you have personal ff 22 knowledge as to the final disposition of the NCR for which t
! 23 those red tags were written?
24 A No. I left too quick, t 25 0 Okay. What -- what date, do you recall? I don't l
lc0
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87' 54
() 1 2
remember the date of these red tags. , I thought we were talking December of the last year, were we?
3 MR. BISHOP: I thought we had talked about the
~
4 second or third week of February.
5 MR. JONES: February was --
6 THE WITNESS: Yes, that's right. Yes.
7 MR. POWER: Okay.
- 8 MR. JONES
- That was my recall, was --
9 THE WITNESS: Very late in February.
10 MR. POWER: All right. I didn't -- I'm just trying s
11 to talk. I have nothing else on the red tags.
~
12 MR. BISHOP: I have one further question that relates
. ,, 13 to the red tags.
14 BY MR. BISHOP:
15 0 This reason reported to you by Mr. Moses for the 16 wanting the removal of the red tags was that it was hampering
- 17 the progress of construction, and you said something about i
j 18 the crafts not having been there long enough to -- to know 19 that under certain conditions they can work through a red tag .
j 20 Could you tell us whether the -- the craft are indoctrinated a
la 21 as to the meaning of a red tag when they come to the Diablo f 22 Canyon site?
[ 23 A I really do not have the knowledge of that becanse
! 24 the QC or QA department is not responsible for the training 25 of the field hands. I mean, that's strictly up to the super-(
t
.E 55
! 1 intendents in charge of the crafts.,,
.2 Q As a quality assurance manager, you didn't have a 3 function of auditing that type of activity?
4 A No, our procedure didn't cover that.
5 Q Based on your experience in the quality assurance 6 field, did the crafts working at Diablo Canyon appear to have
? sufficient training in the area of a general indoctrination 8 of quality requirements in working on a nuclear plant, as 9 far as administrative requirements go, red tags, non-conform-10 ance reports and things of that nature?
s -
11 A I really couldn't -- couldn't make a statement on 12 that. I think there's more qualified people to do that than
. ; 13 me.
(~f'/
\_
14 MR. BISHOP: Okay.
15 BY MR. POWER:
16 Q I'd like to ask some general comments relative to j 17 records, any records relating to nuclear safety put on by 18 H.P. Foley or generated by H.P. Foley. Are you aware of any l E l
i - 19 situations of any possibility of incorrect or falsified rec-(
i j 20 ords of any type at Diablo Canyon?
i g 21 A The NCR.
f 22 MR. JONES: Go ahead.
2
.I 23 THE WITNESS: There was an NCR, non-conformance 24 report, which was generated, as I said before, the morning 25 of December the 3rd, 8 --
i.
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..gN (j 1 MR. JONES: March 3rd. ,,
2 THE WITNESS: March 3rd, I'm sorry, '83. And the 3 non-conformance was roughed out and handed in by Mr. Rick 4 Roan and Michael Cox, who was the supervisor over rod attend-5 ant people, covering the situation, telling exactly what the 6 non-conformance was and how it was caused, relating times, .
7 we were told, relating exactly why we left our station and 8 everything. And the non-conformance now is completely 9 changed. It doesn't cover the rough statements that was to originally put into it. .Th.e non-conformance also states that 11 I was discharged or terminated because of this problem, also 12 Mr. Roan.
, 13 BY MR. POWER:
'(fxl\
14 Q In reference to the specific information pertaining 15 to the technical violation or non-conformance, are you aware 16 of whether or not that is basically the same as it was in the
- 17 first issue? In other words, what I'm saying is if the hill
[.
18 is sliding because of mud or it's raining too much, wha'.ever, h 19 that really has nothing to do with the technical issue per
- 20 se; the issue would be that the weld rods were not maintained 21 in accordance with procedure. So therefore, a roughing out a
f 22 may not have to be necessarily what we would call, quote, "a falsified record." There's a difference. I want you to l 23 24 understand that.
25 A. Y,es.
53
. [
20 37
( 1 Q So that's why I am interested in -- you say it was 2 changed. How was it changed? What were the technical issues; 3 changed in this case?
4 A Well, I think the non-conformance now merely states 5 that weld rod attendants left their station, giving no reasor t 6 for it, breaching security or anything to that effect, and 7 more or less points the finger at Mr. Roan and myself as a being responsible for this situation, not giving any kind of 9 a reason for it.
to Q Okay. I understand what you're saying, but what I s .
11 want you to also is understand is from a Governn.ent point of 12 view that is not necessarily an incorrect or falsified rec-13 ord. We're interested in technical issues.
(.
L 14 A Um hm.
15 Q As to whether or not Jones did it or Mike did it or 16 someone else, that -- that doesn't become a Government issue.
. 17 MR. JONES: Are you asking whether anything was
!. 18 changed with regard to the reporting on the disposition of i
19 the rod itself?
s j 20 MR. POWER: Yes. Yes, the technical evaluation as a a l 21 to how long it was out, you know, when it was out, and this a
f 22 type of nature. That's specifically what we're interested i
g 23 in.
24 THE WITNESS: I don't think there was anything in 25 that -- .
. [
9
_m
21 l
- 53 L x_/
O 1 MR. POWER: You indicated ,,-
2 THE WITNESS: -- line that was changed.
3 BY MR. POWER:
4 Q -- that it is now changed. How do you know it was 5 changed?
6 A I have a copy of the non-conformance.
7 Q The last revised . . .
8 A A revised copy of the non-conformance as to why I 9 was terminated. .
10 Q Is that on the --
s 11 A On the proposed disposition.
12 Q Okay. Do you have a copy of the original NCR, for
.. /^ 13 that date and time, March the 3rd?
k5 14 A A copy of the original?
15 0 Yes.
16 A You mean prior to the rough?
17 Q Yes. No -- well, you said you --
g
'j 16 MR. JONES: The rough draft.
h 19 BY MR. POWER:
c -
lj 20 Q Yes. You said you -- you gave a -- they had a rough ie 21 draft and it told exactly what happened and how it occurred, l
ld 22 and subsequently it was changed. If you have what was origi-3
,! 23 nally roughed out, we would like to see that copy and then l
l 24 the final one that was changed, if you have --
l 25 A I don't have the copy of the rough. But as standard k
l l
. (
l
22 !
39
(( )
. 1 procedure, and has always been with my department in issuing 2 non-conformances, the rough is kept in the file, the Howard 3 P. Foley Company file, along with all pertinent information 4 regarding a non-conformance.
5 0 To the best of your knowledge, the rough then should ,
6 therefore --
7 A That rough -- .
8 Q -- be in the file?
9 A -- should be there.
10 0 In reference to. preparing a rough, in this case 11 I believe you indicated' Roan and Cox prepared the rough.
12 A Yes.
g3 13 Q Is that correct? Is it safe to assume that someone kk_ 14 within your office then types the finalized deal, puts it 15 all together?
16 A Yes.
- 17 Q And you get a number for it. Who has the responsi-j 18 bility for reviewing a rough NCR and determining whether or i
19 not it's valid, whether or not there's sufficient information
- 20 in there? Who performs that function within your staff?
, a a la 21 A That goes to the QA nanager, Mr. Jim Thompson, and d 22 his QAEs, which are his engineers, who will get with possibly a
+
l 23 a person who wrote the non-conformance up, and . . .
24 Q And attempt to determine the --
25 A Yes.
Q(s )
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13 !
30 i 0 -- disposition?
(v\ ;
2 A Yes.
3 Q So what we might possibly have -- and this is my 4 opinion and I don't mean to infer it's yours -- is that What 5 originally started out with the rough draft is considerably 6 different than the finalized report, from what you have been 7 led to believe. It could be possibly be incorrect. Am I --
8 or is lacking in details as to the entire picture --
9 A Lacking in detail.
10 Q All right. . .
11 BY MR. BISHOP:
12 0 Do you think the report as written varies substan-13 tially from a regulatory perspective, as far as identifying 4~
'k/-
O whether there was a compliance or non-compliance with proce-15 dures?
16 A Well, your non-conformance procedure, QCB-3, which 17 is a Howard P. Foley' Company procedure, states in part that i 19 when you write a r.on-conformance you also write in the reason h 19 for the non-conformance --
j 20 MR. POWER: Extenuating circumstances?
THE WITNESS: Right. This was done on the rough.
fE 21 f 22 BY MR. BISHOP:
0 I see. And that doesn't -- didn't appear in the 23 24 final version.
25 A R,ight.
~
l Gs) r-
r l d
. 61 .
j
'- ( ,s) 1 BY MR. POWER: e 2 Q Other than that one instance, are you aware of any 3 situations where there would be any records that could.have 4 been construed by someone as to being falisfied records?
5 I'm not interested in honest mistakes. We realize there --
6 a difference of opinion, supervisors change their word peri-7 odically. I'm Spt :ifically interested in falsified records.
8 That becomes a criminal act.
9 A No, I am not.
10 MR. BISHOP' I hava -- I keep returning to this s
11 issue. I have one more question about the red tag situation 12 that's been discussed for quite some time now.
<~w 13 BY MR. BISHOP:
/'( )
~
14 Q After these tags were turned in to the office,.
15 having been, in your mind, improperly removed, did you or 16 did anyone to your knowledge take action to document this i 17 event in a non-conformance report or any type of official 18
! record? ,
i 19 A 'No , I think at that time.everybody felt the -- well, j 20 this is strictly surmising. But at that time everybody' knew It's
[a 21 if they fought the system, their time was fairly short.
f 22 about all I can say on it, t
[ 23 MR. BISHOP: Okay.
24 BY MR. BURDOIN:
25 o I'd like to ask you a question, Virgil, about those e)
.C t
s
_ . . , _ -- -.. %.- _ . - - - - - - ~ ~ - - - - - - - - - - - - - - - I __ _
62 k.(s) 1 red tags. When those red tags were,,found there in your 2 office that morning, did you have the feeling or attitude, 3 or do you know that the red tags had been properly processed 4 or that they had not been properly processed before remo' val?
5 Maybe it was that they had been properly processed during 6 the night. Is that possible?
7 A No. No, they were -- they were pulled for the 8 reason of -- of letting the -- or requiring the field hands 9 to continue with their work because they were unaware of the 10 procedure and they were afraid to work through a red tag.
s 11 And the red tag situation really, it does scare the field 12 hands out. They -- they don't want to deviate from procedure
. 13 if they -- they possibly know what to do.
) 1: How was it that the management of Foley hoped to O
15 rectify this situation or -- or follow up on the red tags and 16 correct these NCRs?
\. 17 A I do not know. It wasn't discussed with me, John.
j 18 BY MR. BISHOP:
h 19 Q Were the -- did Mr. Moses specifically identify
- 20 which red tags were to be removed when -- when you and he f 21 had the discussion on this subject?
a f 22 A No. No, there was no specific type of red tag or 2
l 23 anything. It was -- he was very adamant about red tag situ-24 ation.
25 Q Okay. How about Mr. Carter, he -- did he discuss V(O
. I 9
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25 g3
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1 with you why he removed those parti,cular red tags, or did ,
2 that amount to all red tags -- what, there were -- you men -
3 tioned there were approximately ten?
' 4 A Mr. Carter told me that he was called up to Mr.
5 Moses' office and told to get those red tags down so that 6 the work'd continue.
7 Q Does that include all red tags that were currently 8 out in the field, hung by the H.P. Foley Company?
9 MR. JONES: If you know. Do you know?
10 THE WITNESS: .No,.I don't.
s 11 BY MR. BISHOP:
12 O Okay. Do you know where these red tags were removed 13 from?
'O -
N# 13 A Not exactly, no.
15 Q Do you know which building they were -- had been 16 removed from?
1 g
17 A I would assume they were fuel-handling building.
l 18 BY MR. POWER:
I i
19 0 Was that where you were then working, H.P. Foley?
- 20 A Yes. Well, H.P. Foley was working all, you know, a
l a
21 the hot lab and --
f 22 Q well --
l 23 A -- fuel-handling building and turbine building, 24 everything at the same time.
25 Q Can you recall any of the individuals that are (i%_
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21 E;4 1
subordinate to Carter, that Carter supervises on the -- his 2 shift?
3 MR. JONES: On the -- on that night in question?
4
! MR. POWER: Yes.
5 MR. JONES: Just the --
6 MR. POWER: We would be interested in talking to 7 them. It's much easier if we know before --
8 MR. JONES: The names of the people, Virgil, that 9 were working for Carter that night?
i 10 THE WITNESS: . Supervisory capacity, or . . .
s 11 BY MR. POWER:
12 O Oh, both. I don't -- I have no idea of the size of e 13 the crowd that would have been working that evening. A couple of each would be sufficient, that we could get, basi-15 cally, an honest evaluation of what occurred the evening of 16 or the morning of -- I don't know, the. hours.that they work.
j 17 A Well, I'd say . . . kind of blank. Mr. Lowell i .
i i 18 Fiddler.
j 19 Q ,
F-I-D-D-L-E-R?
20 A Yes. Was a --
i
- 3 21 Q What's his position?
I t f 22 A -- supervisor over the iron workers inspectors, or s
i
[ 23 civil group, I might say, inspection. Also, Mr. Aguida.
l 24 Q Do you know how to spell his name? Aguida?
l j
25 A (No response. )
kO 1
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25 00
', f'h 1 ! O Is that the best of your knowledge, Aguida?
C,/ ;
2 A Yes. James Aguada.
3 Q What was his position?
4 A The supervisor, in the same capacity.
5 O Can you give us an estimate of the size of crew 6 that would be working that evening for H.P. Foley?
7 MR. JONES: You mean inspect -- in, in quality?
8 MR. L'0WER: Yes, right, in quality.
9 THE WITNESS: I'd say there must have been in the 10 neighborhood of 25 or 30,in that particular group. We were
(
I ti changing people so fast'b'ack and forth that I -- I just l
12 could not keep up with the numbers at that time.
13 BY MR. BISHOP:
I
\ When you say "back and forth," back and forth from s,j 14 Q l 15 what?
l l 16 A Well, from days to nights. I'm sorry, i
- 17 MR. BISHOP: I see. Thank you.
j 18 BY MR. POWER:
3 19 Q They work in two shifts, three shifts?
c
- j. 20 A Two, 10-hour shifts.
a a i 21 0 10-hour shifts.
i f 22 A Six days.
E 23 MR. POWER: And -- okay.
24 BY MR. BISHOP:
25 Q I'd like to change the subject back to another item, NIx-(
. .t
29 66
. \(,
i O) 1 First of all, in terms of background, one thing we didn't 2 ask you at the very beginning, but perhaps.you could address 3 now is, prior to coming to Diablo Canyon were you ever in-4 volved in an -- any other nuclear work?
5 A No.
6 Q Any other work which involved a formalized quality 7 assurance program, such as military, aerospace, and things 8 of that nature?
9 A I worked for Douglas Aircraft.
10 0 In the quality assurance area?
s 11 A No. Production. I worked for' Todd Shipyard, which 12 we were under contract with the Navy.
13 Q Did you work under a quality assurance program there?
(.)
N- u A We worked under a quality assurance program and I 15 did have a -- I was presented a stamp by the quality assur-16 ance department to evaluate my -- my department's work and
- 17 stamp some of it off.
3 18 Q You mentioned that you were a Level 3 inspector.
h 19 What was the basis for you qualification as a Level 3?
z l 20 A It was based en years, number of years experience,
! 21 I guess, related to field in -- field inspection or time in a
f 22 quality assurance and quality control at Diablo, and numerous I 23 quality indoctrinations, workshops, courses, through L. Marvi n 24 Johnson and -- you know, various types like that, as data 25 matrix, and possibly background in the mechanical portion or
~
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1 30 [ g7
(~N l the hands-on work that I had been involved in prior to
( ,) 1 2 coming to Diablo.
3 Q I see. Were you hired as the quality control 4 manager at Diablo Canyon in 1974?
5 A No. I was hired as a quality assurance engineer.
- 6 Q I see. Were you given an ANSI-level quality assur-7 ance level at that point in time, Level 1, 2 or 3?
8 A No, I was never ANSI-leveled until December of . . ,
9 Q '82?
10 A '82. . .
11 Q I see. Okay. 'That's . . . one of the items I 12 wanted to get your professional opinion on was the competency
- 13 of the ins -- your inspection staff up until December '82.
i' 14 Did you feel that there were -- that the inspection staff 15 was conpetent up until that point, or did you feel otherwise?
16 A I didn't really feel it was incompetent because of
. 17 the type of procedures that we working to. Our procedures j 18 were reviewed in and accepted by Pacific Gas and Electric i
19 Company who was monitoring our quality program, and they s
j 20 were approved, the proce -- all procedures were approved by 21 Pacific Gas and Electric Company prior to being instituted.
$ 22 So any inspection that was done, if a -- we took some -- we l 23 did hire some inexperienced people, but they were indoctri-24 nated and they were not turned loose in the field until we 25 felt they,-- they could perform their task properly and fill
- J t
4
3'l , , ,
oo
-?("') 1 out their forms and document. But ,they were signing off 2 their own inspections at the time we did turn them loose in-3 the field on their own.
4 0 I see. We've talked about several issues so fa'r 5 today. We've talked about the red tag issue, we've talked 6 about inspection staff confiden -- competence, and we've 7 talked about the weld rod control issue that occurred in the 8 latter part of February and early March of '83. Were there 9 any other instances that you have knowledge of where quality 10 requirements were not properly followed within the area of s -
11 jurisdiction of H.P. Foley Company at Diablo Canyon?
12 A None that I'could specifically call out right now,
, 13 but they are all on file within the Pacific Gas and Electric (O
Es/ " Company's audit group. I mean, their QC and their QA per-15 formed audits and did write procedural violations up against 16 the Howard P. Foley Company.
g 17 0 Were there any of these instances which to your l 18 knowledge were not properly followed up?
g 19 A Not to my knowledge.
- 20 0 Is there anything else that you feel we should be a
h 21 aware of in relation to the Diablo Canyon activities?
8 f 22 MR. JONES: Here I am going to instruct you to i
- 23 confine your answer to technical issues rather than anything 24 that affect -- that bears upon your own termination.
25 MR. BISHOP: That's principally our concern, is --
(.
v
. I
2 g3 n(~)N N-
- ' 1 MR. JONES: Yes, that's - ,, -
2 MR. BISHOP: -- is the technical issues.
3 MR. JONES: I understand that.
4 THE WITNESS: I. . .
5 MR. JONES: Go ahead.
6 THE WITNESS: I . . .
7 BY MR. POWER:
8 Q Do you have any, any situations --
9 A No, I have nothing at this time.
10 Q Okay. . .
g 11 MR. BISHOP: Okay.
12 BY MR. POWER:
i
,(
s_-
13 Q I previously believe, if you're getting close to
?4 the end, that you previously made a comment relative to the 15 possibility of a problem concerning security guards or the 16 security system at Palos Verdes that you had direct knowledge g
17 of. Was that previously discussed?
l 18 MR. BISHOP: I believe you mean Diablo Canyon.
h 19 MR. POWER: Diablo, okay. Palos Verdes, we're down j 20 there a lot.
a l
8 21 BY MR. POWER:
6 f 22 Q At Diablo. Were there any other concerns or issues 23 that you wanted to raise relative to the implementation of 24 security at --
25 A No, none.
(,
=
t 4
. . - , , ~ _ _ , - - - - _ . _ - . _ - - . - . , __ . . . --
3'3 70
~
1 4.'(\_,-) 1 Q Okay. I didn't know if the incident we previously 2 discussed covered the issue.
3 A Other than -- we were very careful not to breach 4 security. We --
5 Q All right. So the best --
6 A -- we were cautioned --
7 Q -- of your knowledge --
8 A -- many times, " Don't breach security." And --
9 0 Yes. No problems, no known violations of . . .
10 A None to my knowledge.
s 11 Q Okay.
12 BY MR. BISHOP:
13 0 I guess I really have only one general comment that i k 'g/
~
14 I wanted to get your impression on, and I'm sure with your 15 broad background in the construction area you're familiar 16 with normal job pressures that are associated with any large 17 construction task. And sometimes those construction pres-g l 18 sures are misinterpreted and result in actions contrary to i
19 the quality requirements of the project. In this instance j 20 you mentioned the removal of the red tags where a specific a
! 21 instruction was given which you relate to excessive pressure a
d 22 by a senior member of the Foley site management team. What e
[ 23 would you -- bow would you characterize the pressures, the 24 other instances of pressures? Were they more than would be 25 expected at a construction project with tight schedules?
ss_-
1
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\ k.,-)/ 1 MR. JONES: Virgil, I thing in answering that you 2 should confine yourself to comparing tha pressure that you 3 experienced there to the pressures you experienced at other, 4 other positions you've held. I don't really think you should 5 speculate about the -- you know, the construction industry 6 in general.
7 MR. BISHOP: That would be fine.
8 THE WITNESS: Well, I think I -- I don't think I've 9 ever had the pressure and been put in a position I have on 10 this job. I've never had it on any other job. No.
s 11 BY MR. BISHOP:
12 O Would you say that that pressure up until the latter 13 part of February, 1983, was such that it created any kind of
'.7 b 14 a cuality problem at Diablo Canyon?
15 A I really can't answer that one.
16 MR. JONES: Well, are you asking him whether as the 17 result of the pressure he did -- he did anything different j 18 than he might have wanted to do it?
h 19 MR. BISHOP: No. I'm asking him, as a result of the i :
- j 20 pressure, were there instances where the quality program i
21 requirements were violated up until the February '83 time d 22 frame?
t 3 23 THE WITNESS: Why, we had a number of procedural 24 violations, yes, which were recorded and are in the files at 25 this time under the very non-conformance and IR program that C[v
.I
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i 35 ,. , j
. q,,) 1 we had.
, 2 BY MR. BISHOP:
3 0 Would an examination of those records indicate the 4 cause was excessive pressure?
5 A I can't really answer that one. I . . . no , I can ' t.
6 -- I can't surmise. I think everyone would look at it, maybe 7 interpret it a little bit differently.
8 MR. BISHOP: I have no further questions. Do 9 either . . .
10 MR. POWER: Ng,.I,have no other questions.
11 MR. BISHOP: John?
12 MR. BURDOIN: No, I don't have any.
e~ 13 MR. JONES: Okay.
kk-)
14 MR. POWER: Unless you would like to raise some 15 other issue, Virgil?
16 MR. JONES: No, this is --
- 17 THE WITNESS: No, I have nothing --
2 l 18 MR. JONES: This is their party. Let them raise i
19 the issues.
i 0
I j 2C THE WITNESS: I have nothing.
21 MR. POWER: Okay. The time I have is, what -- 1556?
l f 22 MR. BURDOIN: 1556 is good enough for me.
t
,5 23 MR. JONES: Well, can.we talk off the record here?
24 You're going to stop the record now?
25 Oh, yes. We're off the l MR. POWER: . . .
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$* i i 36 73
}
I' g 1 THE REPORTER: Off the record?
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2 MR. POWER: Off the record.
\
4 3 (whereupon, at 3:56 p.m. , the interview was closed. )
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i O ATTACHMENT 2 l
NRC REGION V INSPECTION REPORT, 3 Dated May 19, 1983 i
's
!O l
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/ o UNITED STATES
! o NUCLEAR REGULATORY COMMISSION
.n S REGION V O g 1450 MARIA LANE,sulTE 210 Y, ,d WALNUT CREEK. CALIFORNIA 94ME ,
i **"'
MAY 191983 Docket Nos. 50-275 50-323 Pacific Gas and Electric Company
. ;- P. O. Box 7442
- San Francisco, California 94120 Attention: Mr. Philip A. Crane Jr.
Assistant General Counsel Gentlemen:
This refers to the special inspection, conducted by Messrs. J. D. Carlson, G. H. Hernandez, and M. M. Mendonca of this office during the periods of March 30 - April 6 and April 25-29, 1983, of activities authorized by NRC License No. DPR-76 and Construction Permit No. CPPR-69, and to the discussions of our findings with Mr. F. W. Mielke and other members of the Pacific Gas and Electric Company staff at the conclusion of the inspection.
t x-- The inspection was an examination of concerns expressed or implied by former employees of the Howard P. Foley Company related to alleged excessive production pressure and the alleged effects on the quality of construction activities; procedural adherence; and the certification / qualification of inspection and craft personnel. Within these areas, the inspection consisted of selected examinations of procedures and representative records, interviews with personnel, and observations by the inspectors. 3 3 -
As indicated in the e'nclosed report the majority of the concerns were not substantiated. However the special inspection did identify three areas where you failed to comply with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A. Based upon the specifics of paragraph B of the Notice of Violation, attached herewith as Appendix A, and upon interviews of H. P. Foley personnel it appears that the discrepant methods used by H. P. Foley to conduct welder recertification examinations may not have been an isolated case. Therefore, in addition to your response to that particular violation you are requested, for all site contractors currently engaged in ASME B&PV Code welding, to: (1.) provide an assessment of the degree to which your welder requalification procedures and implementation practices, employed both in the past and at present, comply with the requirements of the ASME B&PV Code; and (2) the affect on welding quality of any identified failure to comply with Code requirements.
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l 2 j, g Pacific Gas and Electric Company In accordance with 10 CFR 2.790(a), a copy of this letter and enclosures will be placed in the NRC Public Document Room unless you notify this office, by -
telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1).
The responses directed by this letter and the accompanying notice are not subject to the clearance procedures of the Office of Management and Budget as .
required by the Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be glad to discuss them with you.
Sincerely, l
g T. W. Bishop,'
Reactor Chief Projects Branch No. 2 l
l
Enclosures:
Notice of Violation v A.
B. NRC Inspection Report No. 50-275/83-13 50-323/83-10 cc w/ enclosures: '
G. A. Maneatis, PG&E W. A. Raymond, PG&E R. C. Thornberry, PG&E (Diablo Canyon)
R. D. Etzler, PG&E (Diablo Canyon)
O
APPENDIX A NOTICE OF VIOLATION Pacific Gas and Electric Company Docket Nos. 50-275 and 50-323 License No. DPR-76 and '
P. O. Box 7442 Construction Permit No. CPPR-69
'. San Francisco', California 94120 As a result of the special inspection conducted during the periods of March 30- April 6 and April 25-29, 1983, and in accordance with NRC Enforcement Policy, 10 CFR Part 2, Appendix.C, the following violations were identified:
A. 10 CFR 50', Appendix B, Criterion V, as implemented by Section 17.1.5 of the FSAR and the PG&E Quality Assurance Manual,Section V, states, in part, that, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings...and shall be accomplished in accordance with these instructions, procedures or drawings...."
- 1. The Howard P. Foley Quality Control Procedure for Processing and Control of Deviations and Nonconformances, QCP-3, Revision 5, states, in paragraph 4.3 that, "When a nonconformance is noted, it l ,
shall be processed in accordance with this procedure on areports
! These Nonconformance Report by the Quality Department.
require Pacific Gas and Electric Company review and acceptance."
l Paragraphs 4.3.1 through 4.3.10 of QCP-3 describe the review culminating withand l approval cycle of the nonconformance report, l \
paragraph 4.3.11, which states that, "When all of the above steps (paragraphs 4.3.1 through 4.3.10) have been completed the f Nonconformance Report shall be forwarded to Quality Engineering who shall coordinate removal of the Hold Tag (s) and file the report in the Quality Files."
I Contrary to the above, discussions held with the then Acting Quality ,
Control Manager on March 31, 1983, identified that " Red Hold Tags",
attached to structural steel I-beams at the 187' elevation of the Unit 2 Fuel Handling Building, and documented o,r, Nonconformance Report No. 8802-803, Revision 1, were removed by him from approximately ten of the fifteen locations on or about January 29, 1983. The tags were removed prior to completion and approval of the entire nonconformance report. Nonconformance Report No. 8802-803 was formally approved, completed and signel on March 16, 1983.
This is a Severity Level V Violation (Supplement II), applicable to Unit 2.
- 2. The Howard P. Foley Quality Control Procedure for Welder and Brazer Qualifications and the Qualification of Welding and Brazing l
j Procedures, QCP-5, Revision 8, states in paragraph 5.1 that, " Welder l qualification shall be effective providing the welder has used the 6 months l
process qualified for within "B", the "C",
following "G" orperiods:for "E", andtime 3 w "I"."
l l
months for welders qualified under Appendix
l s_ .
Appendix C of the procedure describes the steps necessary to qualify a welder to the AWS DI.1, Structural Welding Code, latest revision, -
for groove welds of unlimited thickness. Successful completion of this qualification test also qualifies the welder for welding fillet welds on material of unlimited thickness. QCP-5 further states in paragraph 5.1.1 that, "The Quality Control Department shall monitor each welder for each process qualified within the time period above, to ensure that the welder's qualifications do not lapse."
Contrary to the above, as of March 31, 1983, H. P. Foley Company welder, (symbol "JX") had not completed the process requalification which was due to be completed on January 27, 1983. The welder was initially certified on February 29, 1980 to a AWS D1.1 Shielded Metal Arc Welding (SMAW) Process and monitored by Quality Control every six months afterwards, with the last process qualification performed on July 27, 1982. The welder was included on H. P. Foley Active Welders List and was performing as a qualified welder as of March 31, 1983.
This is a Severity Level IV Violation (Supplement II), applicable to Unit Nos. I and 2.
( B. 10 CFR 50, Appendix B, Criterion IX, as implemented by Section 17.1.9 of the FSAR and the PG&E Quality Assurance Manaual,Section IX, states that,
" Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements." 7 The 1980 Edition of the ASME Boiler and Pressure Vessel Code,Section IX, j
" Welding and. Brazing", Subarticle QW-322, " Renewal of Qualifications",
' states that, " Renewal of qualification of a performance qualification is required: (a) when a welder or welding operator has not used the specific process, i.e., metal arc, gas, submerged arc, etc., for a period of three months or more; except when employed on some other welding process, the period may be extended to six months; or (b) when there is a specific reason to question his ability to acke welds that meet the specification. Renewal of qualification for a specific welding process under (a) above may be made in only a single test joint (plate or pipe) on any thickness, position, or material to re-establish the welder's or welding operator's qualification for any thickness, position, or material for which he was previously qualified.
Contrary to the above, on April 27, 1983, the NRC inspector identified that a H. P. Foley Company Welder (symbol S-4) had been improperly recertified, on February 19, 1983, to ASME Welding Procedure Specification (WPS) No. M-03, a Gas Tungsten Arc Welding (GTAW) process. Quality
(}/
x, records indicated that recertification was accomplished by having the
l i
welder strike an arc with the nonconsumable tungsten electrode long enough for the H. P. Foley Quality Control Inspector to take amperage and _
voltage readings and record these on an In-Process Welding Inspection
- Report. The report also indicates that no weld rod was issued during this time. The signature of the Quality Control Inspector on the In-Process Welding Inspection Report indicates acceptance of recertification of the welder to the particular welding process. This particular welder was listed on the H.P. Foley Active Welders List dated April 27, 1983. An examination of employer payroll and weld rod withdrawal records indicated that this welder was promoted to foreman on January 18, 1983 and had performed no welding since that date, though he was considered qualified and able to perform, as a result of the recertification test on February 19, 1983.
This is a Severity Level IV Violation (Supplement II) applicable to Unit Nos. I and 2.
Pursuant to the provisions of 10 CFR 2.201, Pacific Gas and Electric Company is'hereby required to submit to this office within thirty days of the date of this notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.
MAY 191983 D.
gjF.' Rtfsch, Chief ,
Date
- Reactor Projects Section No. 3
. a i
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U. S. NUCLEAR REGULATORY COMMISSION REGION V s Report Nos. 50-275/83-13 50-323/83-10 Docket Nos. 50-275 and 50-323 ,
License No. DPR-76 Construction Permit No. CPPR-69
. Licensee: Pacific Gas and Electric Company P. O. Box 7442 San Francisco, California 94120 Facility Name: Diablo Canyon Unit Nos. I and 2 Inspection at: Diablo Canyon Site, San Luis Obispo County, California Inspection Conducted: March 30 - April 6 and April 25-29, 1983
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Inspectors: ~ .~f'.bhq b,CT- .Q s/ 4_83 J. D. Carlson, Senior Resident Inspector Date Signed
. W Ab w k, 5 /M A93 Date Signed
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H.Hernandez,ReagprInspector YY g M. M. Mendonca, Resident Inspector .
fldkN Dat'e Signed Approved by: [f F D. T. Y rsch, Chief Dfite Signed Reactor Projects Section No. 3 Summary: ,~
Inspection during the period of March 30-April 6 and April 25-29, 1983 (Report l
Nos. 50-275/83-13.and 50-323/83-20)
Areas Inspected: Unannounced special inspection by the two resident inspectors and one regional inspector of general and specific concerns expressed or implied by two former Howard P. Foley Company employees related to: excessive production pressure, control and handling of nonconformance reports, welding and welding inspection, and certification / qualification of persoanel.
l l The inspection involved 242 inspection-hours by three NRC inspectors.
Results: Of the areas examined three items of noncompliance were identified:
Failure to comply with procedural requirements for the processing of nonconformance reports (paragraph Sc ), failure to requalify a welder in accordance with Code and procedural requirements (paragraph Se ), and failure to assure that measures are established to recertify welders in accordance with code requirements (paragraph 6).
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TABLE OF CONTENTS I Paragraph Title Page.No.
- 1. Individuals Contacted 1
- 2. Background 1
- 3. NRC Response 2
- 4. NRC: Region V In-Office Inspection Effort 2
~
- 5. Summary of Concerns as Understood by NRC 3 Sa. Concern Regarding Excessive Production Pressure 3 Sb. Concern Regarding Red Hold Tags in Fuel Handling Building 3 Sc. Concern Regarding H. P. Foley's Compliance With 5 10 CFR 50, Appendix B Sd. Concern Regarding Certification of Quality Assurance 6 Auditors and Quality Control Inspectors Se. Concern Regarding Welder Certification 8 Sf. Concern Regarding NCR No. 8802-819 9 Sg. Concern Regarding General Compliance to Procedures 10 for Controlling Nonconformance Reports Sh. Concern Regarding Weld Quality 11
~ Si . Concern Regarding Routing of Instrumentation Tubing and F1 Electrical Conduits Sj. Concern Regarding the " Quick Fix" and Engineering Disposition 12 Request Programs l Sk. Concern Regarding High Ozone Levels in the Fuel Handling 13
/)
. Building Affecting Weld Quality (m / 51. Concern Regarding Excessive Work Hours Affecting Work Quality 14 Sm. Concern Regarding Independence of the H. P. Foley's QA/QC 14 Organization Sn. Concern Regarding Installation of Nonconforming Material 15 So. Concern Regarding Water in Conduits Leading to the Intake 16 Structure - ;
5p. Concern Regarding Weld Quality on the Fuel Handling Building 16 '
Structural Steel Sq. Concern Regarding,the H. P. Foley Quality Assurance Program 17 Prior to 1974 Sr. Concern Regarding the Ability of the Crafts to Work With 19
" Mirror Image" Design Drawings 5s. Concern Regarding Inspector to Worker Ratio 19
- 6. Additional NRC Inspections 20
- 7. Unresolved Items 21
- 8. Exit Interview 22 A
b
DETAILS
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- 1. Individuals Contacted ,
- s. Pacific Gas and Electric Company (PG&E) .
+ F. W. Mielke, Chairman of the Board
+*R. D. Etzler, Project Superintendent D. A. Rockwell, Assistant Project Superintendent W. A. Coley, Resident Electrical Engineer F. M. Russell, Resident Civil Engineer V. O. Smart, Electrical Inspector
+ R. T. Twiddy, Quality Assurance Supervisor
+ W. A. Raymond, Quality Assurance Manager
+ R. C. Thornberry, Plant Manager ,
+ J. D. Shiffer, Manager, Nuclear Plant Operations
+ R. Luckett, Regulation Compliance Engineer
- b. Bechtel Power Corporation (Bechtel)
~~~
+*J. W. Shryock, Site Completion Manager
- c. Howard P. Foley Company (Foley)
+ F. Lench, Regional Vice-President
+ P. J. Bourque, Project Director O
+*A. E. Moses, Senior Project Manager
[ +*R. Wilson, Quality Director
! + J. L. Thompson, Quality Assurance Manager I
+ T. Canning, Quality Control Manager R. A. Carter, Assistant Quality Control Manager S. J. Ryan, Quality Assurance Engineer ,- .
l H. R. Rowland, Electrical Manager W. McCreery, General Superintendent L. Fidler, Quality Control Supervisor C. Agueda, Night Quality Control Supervisor R. G. Meek, Quality Control Supervisor G. Jackson, Ironworker Foreman R. Spencer, Quality Control Inspector I
i Several other Quality Control and Craft Personnel were also interviewed during the course of the special inspection.
- Denotes personnel attending the exit management meetir.g of April 6, 1983.
+ Denotes personnel attending the exit management meeting of May 12, 1983.
- 2. Background On March 3, 1983, the NRC became aware that a senior level individual, involved in Quality Control, had terminated employment with the Howard P. Foley Company at the Diablo Canyon site. At about the same time, the NRC became aware that a second individual involved in Quality O Control had terminated employment with the H. P. Foley Company. In
- n .__ _ _ _ _
4 order to establish whether the circumstances of that termination
'() were related to the improper implementation of the H. P. Foley Quality Assurance Program, the senior level individual was interviewed, by an NRC Investigator and Branch Chief, on March 25, 1983. The interview was conducted under oath, in the presence of his attorney and the interview recorded by a qualified reporter. -
The concerns expressed or implied by the individual and the NRC findings are addressed in paragraph 5 of this report.
On April 5,1983, representatives of the Attorney General of the
. State of California interviewed the two former H. P. Foley Company quality control employees that had terminated employment with the H. P. Foley Company on March 3, 1983. This interview included the former H. P. Foley Quality Control Manager who had been interviewed by the NRC on March 25, 1983. The testimony was recorded by a qualified court reporter and a transcript provided to the NRC. The concerns expressed or implied in the transcript are addressed in paragraph 5 of this report.
- 3. NRC Response
~
A team of three NRC inspectors conducted a special inspection at the Diablo Canyon Nuclear Power Plant site, during the period of March 30 - April 6 and April 25-29, 1983. This inspection included an examination of procedures; an examination of quality control inspector, auditor, and welder certifications; and interviews of personnel referred to by the former H. P. Foley Company employees in O. . their testimony. The interviews of personnel at the site were conducted at the onsite office of the NRC resident inspector and included all personnel mentioned in the testimony and now presently employed by the H. P. Foley Company. The former Assistant Quality Control Manager for H. P. Foley, who terminated employment on the same day as the Quality Control Manager, was contacted (by telephone) to provide an opportunity for the individual to express ,-
j his concerns or reservations with the quality of the H. P. Foley construction activities. Though an appointment was made and agreed upon with the individual, he failed to present himself for the inte rview. Further attempts by the NRC to contact this individual have not been successful.
- 4. NRC: Region V In-Office Inspection Effort NRC inspection records were examined to address certain areas of concern, as expressed by the former H. P. Foley Company Quality Control Manager (H. P. Foley activities are addressed in approximately 50 NRC inspection reports between 1971 and 1983). ,
The records related to NRC reviews of various aspects of the H. P.
Foley Quality Assurance Program and its compliance with AEC/NRC regulatory requirements, including 10 CFR 50, Appendix B. The inspector noted that AEC/NRC Inspection Report dated May 6, 1971 (no inspection report number was assigned) examined the H. P. Foley Quality Assurance Program for the electrical and instrumentation O currently in progress (Contract Specification No. 8807) and concluded that a suitable QA/QC program had been developed and was in place.
P
, . _ _ - . _ = - - - .
- 5. Summary of Concerns as Understood by the NRC
- a. Concern: The concern was expressed or implied that excessive f 4
production pressure, which allegedly manifested itself in the form of threats and intimidation toward quality personnel, ,
subsequently resulted in by passing of established quality '
control hold points and procedures.
NRC Findings: This concern was not substanti~ated.
A specific instance involving the violation of procedures for resolving a nonconformance report was identified. However, this
- item was not determined to be the result of harassment or threats by production management. This item is discussed i separately in paragraph Sb.
To establish whether the concern of threats and intimidation toward quality personnel had substance, interviews were conducted with several H. P. Foley personnel including the Project Manager, the Acting Quality Control Manager, the
'j Quality Assurance Manager, a number of Quality Control Supervisors, Inspectors, Iron Workers and Iron Worker Foremen.
~
These interviews centered on whether any of these individuals
- had knowledge of any threats or intimidation directed toward
- themselves or quality and craft personnel in order to enhance
- production to the detriment of quality. While all personnel interviewed acknowledged a certain amount of pressure to expeditiously complete assigned tasks, none expressed any
.O knowledge of threats or intimidation made either to themselves or in their presence. None of the personnel interviewed expressed any knowledge of directives from production management to by-pass quality control hold points, deliberately violate procedural requirements, and/or falsify quality records. ,1 -
4 One item of noncompliance was identified during these interviews and is discussed in paragraph Sb.
- b. Concern: The specific concern was expressed that near the end of 1982 approximately ten " Red Hold Tags" attached to nonconforming material in the Fuel Handling Building were l removed by the night shift Assistant Quality Control Manager in violation of procedural requirements.
NRC Findings: This concern was substantiated.
4 I
In addressing the specific concern that approximately ten " Red Hold Tags," had been removed from the Fuel Handling Building in
- violation of procedural requirements, the inspectors first attempted to locate and examine the subject tags. Testimony by the former Quality Control Manager indicated that the tags in question had last been seen in the H. P. Foley Quality Control Manager's office.
i
On March 30, 1983, the NRC inspectors conducted a search, of
.. the H. P. Foley Quality Control Manager's office. The subject -
( tags were not lecated. Discussions with H. P. Foley personnel indicated that the subject tags were probably destroyed after completion and approval of the associated nonconformance .
report. The H. P. Foley Quality Control Procedure for Processing and Control of Deviations and Nonconformances, QCP-3, does not require the retention of " Red Hold Tags" as quality records.
The interview with the new Assistant Quality Control Manager indicated that the " Red Hold Tags" in question dealt with nonconformances in the Unit 2 Fuel Handling Building where gouges had been made on about 15 structural steel beams during removal of grounding pads (connections to the structural steel for electrical equipment grounding). All of the nonconforming beams were documented on Nonconformance Report (NCR) ,
No. 8802-802 and each beam was tagged with a " Red Hold Tag" referencing NCR No. 8802-802. The repairs of these gouges had proceeded to the point where much of the work was completed, though a few beams still required repair. The work on the already repaired beams had been accepted by Quality Control, -
but in accordance with procedural requirements, as ccntained in H. P. Foley Procedure No. QCP-3, none of the " Red Hold Tags" could be removed until the repair work on all of the beams was
! accomplished, accepted by Quality Control and the appropriate approval signatures obtained from H. P. Foley and PG&E engineering.
As indicated in the testimony of the former Quality Control Manager, craft personnel were and are extremely hesitant to work near or around " Red Hold Tags." Production supervision, on or about January 29, 1983, requested (of l
Quality Control) that " Red Hold Tags", attached to beams on 3 which work had been inspected and accepted, be removed so that craft personnel could proceed with regularly scheduled work in the area. The new Assistant Quality Control Manager (at the I time the night shift Assistant Quality Control Manager), upon reviewing the completed and accepted work, removed the " Red Hold Tags", for those beams where the work had been inspected and accepted by Quality Control. During the interview, the Assistant Quality Control Manager indicated that he did not, nor did he at the time of the interview, recognize this action as a violation of Quality Control Procedure QCP-3. The individual specifically stated that the removal of the " Red Hold Tags" (by him) was not done as a result of threats or initimidation by production management. The removal of " Red Hold Tags" prior to final approval of the entire nonconformance report appears to be a procedural violation of QCP-3. H. P.
Foley Quality Control Procedure for Processing and Control of Deviations and Nonconformances, QCP-3, Revision 5, states in paragraph 4.3.11 that, "When all of the above steps (the steps delineating the review and approval cycle of the nonconformance O report) have been completed the Nonconformance Report shall be
forwarded to Quality Engineering who shall coordinate lity removal
- s/ f, of the " Red Hold Tags" and file the report in the Qua The failure to comply with quality procedures;foridered Files."
controlling and processing nonconformance reports i is V,. c6ns i
an apparent violation of 10 CFR 50, Appendix B, Cr ter on(50-323/83-10/01)
" Instructions, Procedures or Drawings." ~
The concern was expressed or implied Code ofthatFederal H. P.'Foley
- c. Concern:
was not required to comply with Title 10 of the l Regulations, Part 50 (10 CFR 50), Appendix B (Quality Assurance requirements).
l NRC Findings: This concern was not substantiated.
An examination of H. P. Foley's Quality Assurance Program in effect since September 4, 1970.
1970, the Quality Assurance Manual for their first contract (Specification No. 8807) was approved by Pacific Ga Electric. dix B.
contained in the then recently issued 10 CFR 50, Appen
, 10 1970.
,CIlt 50, Appendix B was issued by the AEC/NR their areas of responsibility and the compliance of H. P. Foley's Quality Assurance to 10 CFR 50,SqAppendix of this B requirements up to 1974 is further described in item l
O report.
On October 16, 1974, the U. S. Atomic Energy Commission (AEC) issued their Safety Evaluation Report on the Diablo Canyon Nuclear Power Station Units 1 and 2. Paragraph 17.4 of this report states in part that: f f f
"As a result of our detailed reviewithand the evaluatio l the FSAR and a series of discussions and meetings w f PG&E applicant, we conclude that the QAhorganization e conduct the QA Program without undue influence d from t os organizational elements responsible for cost an schedules."
In addition, Supplement No. 3 to the in paragraph 17.3Safety states, Evaluation in part, Report, dated September 18, 1975, that:
"The qu.Aity assurance program for plant operation of Diablo Canyon, Units 1 and 2, complies with the guidance contained in WASH-1283 (May 24, 1974), " Guidance on Quality Assurance 26, 1973), " Guidance on Quality Requirements During Des WASH-1284 (October Assurance Requirements During the Operations Phase of (s Nuclear Power Plants"; and WASH-1309 (May 10, 1974),
i
" Guidance on Quality Assurance Requirements During This the
()
.s Construction Phase of Nuclear Power Plants."
complies with our position on the implementation of guidance in quality assurance programs and'is, therefore, acceptable.
Based on our evaluation as described in the Safety ,
Evaluation Report and supplemented in this report, wr now conclude that the Diablo Canyon Quality' Assurance Pre;rsm has the necessary controls to comply with the requirements of Appendix B to.10 CFR Part 50 and is, therefore, acceptable for controlling the operational phase of Diablo Canyon, Units 1 and 2."
Pacific Gas and Electric Company, in Chapter 3, paragraph 3.2.1, of the Final Safety Analysis Report (FSAR), states that:
" Appendix B to 10 CFR 50, " Quality Assurance Criteria fer Nuclear Power Plants and Fuel Reprocessing Plants,"
requires that structures, systems, and components important to safety be designed and constructed in accordance with the quality assurance requirements described in Appendix B. Therefore, as described in Chapter 17 of the FSAR, the requirements of the Diablo Canyon Quality Assurance Program apply to all structures, systems, and components classified as Design Class I, this assures that plant features important to safety have met
(g the requirements of Appendix B." .
( ,/
Chapter 17, of the FSAR states in paragraph 17.1.2 that:
" Pacific Gas and Electric Company's Quality Assurance J. -
Program requires that all contractors and suppliers of Design Class I items establish and maintain in effect quality assurance programs appropriate to the importanceRequirements fo of.their activities important to safety.
contractors' and suppliers' quality assurance programs are Specified prescribed in design specifications.
requirements are based on 10 CFR 50, Appendix B.
Contractors and suppliers are not permitted to proceed with their work until they have submitted a quality assurance manual describing their quality assurance program and have received approval from PG&E."
Based upon the above it is apparent that the H. P. Foley Company was required to implement a Quality Assurance Program as required by 10 CFR 50, Appendix B.
l 6
No items of noncompliance or deviations were identified.
l Concern:
The concern was expressed or implied that H. P. Foley d.
O quality control inspectors and quality assurance aud l
l l
- 7_ ,
of Inspection, Examination,.and Testing Personnel for the l- 4 Construction Phase of Nuclear Power Plants", and ANSI N45.2.23, -
" Qualification of Quality Assurante Program Audit Personnel for Nuclear Power Plants", respectively. -
NRC Findings: This concern was not substantiated.
s .
To address this concern the inspectors reviewed the qualification program for quality personnel working for the Howard P. Foley Company. This examination indicated that the program for qualification of personnel was specified and
' controlled by H. P. Foley Quality Control procedure QCP-6
" Indoctrination and Training," Revision 5.0, prior to
- December 1982.
This procedure specified the indoctrination process and job-related training requirements leading to certification as a fully qualified inspector. However, this program did not specify levels of qualifications and educational requirements, as required by ANSI N45.2.6, for quality control inspectors, The and ANSI N45.2.23, for quality assurance auditors.
inspector reviewed the licensee's quality assurance program that was in ef fect at the time (before December 1982) and determined that ANSI N45.2.6 and N45.2.23, were not a
[
commitment of the licensee's program and thus were never imposed on the contractors. On May 4, 1981, the NRC issued
() -
generic letter 81-01 which required all licensees of operating plants and holders of construction permits to endorse ANSI N45.2.6 for quality control inspectors and ANSI N45.2.23 for quality assurance auditors. The licensee responded in a letter, dated July 14, 1981, and committed to implement the
' above standards with minor exceptions prior to full power licensing of Unit No. 1. In August 1982, the licensee l
conducted a quality assurance audit (PG&E Audit No. 20801) of J. .
the H. P. Foley Quality Assurance Program and an audit finding was written 'against the H. P. Foley Quality Control / Quality
- Assurance Training Program for inspectors and auditors. In response to the raudit findings, H. P. Foley generated a new procedure (QCP-6A) for qualification and certification of
' quality control inspectors and supervisors that follows the guidelines of ANSI N45.2.6. In addition, a new procedure has been drafted addressing the qualification of quality assurance
~
auditors in accordance with ANSI N45.2.23.
The inspectorsteviewed the H. P. Foley qualification records for the Quality. Control Manager, Quality Control Inspectors, Superv'isors, Quality Assurance Auditors, Lead Auditors and the Quality Assurance Manager. Under the requirements of H. P.
Foley Quality Control' Procedure QCP-6, in effect at that time, the qualification records were satisfactory. However, a problem with implementing the new certification process required by the new procedura (QCP-6A) was identified by the licensee. In late December 1982, the H. P. Foley Company contracted with Cataract Engineering Company to supply
?-----,.--.,,._._,,_ _
i
~
l ThesepersonnII,were additional quality control personnel.
certified to a certain level by Cataract based on experience However, the resumes and verified by an investigative service.
of the individuals, in some cases, did not support the -
This problem was identified by.
certifications in some areas.
licensee Quality Assurance Audit No. 83043A, performed in February 1983, and further documented on Nonconformance Report No. 8802-824, dated March 17, 1983. Currently the licensee, "t
+ - ,
the H. P. Foley' Company,'and Cataract Engineering Company are resolving the problem hy verifying past employment of the [
i personnel in que'stion/ 'In the interim, personnel with a potential resume problem are not being used in the field asThis nonco
~
qualitycontrolir.r.pectdrr/.alsc/ note 3;that between December 7,1982 a No. 8802-024)
March 10, 1983, Level I~ inspection did not require a Level II co-signature, and further notes that, ,"This nonconformance encompasses both H. P. Foley direct inspection personnel The and sub-contracted", Cataract Engineering'C$npany personnel."
resolution of these licensee audit'findirgs will be examined during a future inspection. (50-275/83-13 . ' ' 91)
<, 1
' a ,
No items of noncenpliance or deviations were identified.
Concern:
The concern was expressed or aplied that as a result e.
l of increased construction activity starting in September 1982 and the accelerate 4Lhiring of craf t personnel, welders hired during this period zeight not be properly certified.-
'; p Nht Findings: The specific concern that welders hired since I
,_, September 1982 sight-not be properly certified d was nots welder certificatica,was identified during this examination an
/'6 f a c /<
is detailed below. '
i
~
i To' address this concern the inspectprs Examined H. P. Foley's
/ /
' Quality Control Procedure for Welde'r and Brazer Qualifications and the. Qualifications,of Welding and Brazios Procedures
','- (QCP-5, Revision 8, dated 1/28/82) and determined that the r
procedure provides a system for qualifyin'g velders an
- g. The procedure refer-nces and appears to comply with welders.
/'f the latest edition of the AWS D1.1, Structural Welding Code, steps necessary
,l, for documenting test results and' describes thr:
l i ,
to qualify a procedure and a welder in accordance with Code l ,'
requirements.
/r y ~
, i .
An exa'n'ination of the qualification records for seventeen
~
,, o / 4 wa:1ders (ironworkers, pipefitters, and electrical welders)
-edteblished that all of the welders certified since September 19&li.ad been properly certified and monitored in accordance11c with requirements of QCP-5.
' one electrical welder (symbol "JX"), initially certified on Yebruary" 27, 1980 to an AWS DI.1 Shield Metal Arc Welding I
c (SMAW) Precess, had last been monitored by Quality Control on
\ , ,,
a l
5 ,
- a f, _
! H. P. Foley procedural requirements specify July 27, 1982. -
that Quality Control must perform process monitoring for AWS D1.1 weldingeev, ry six months for each welder to assure thatThis weld welder qualifications do not lapse.be included 31, 1983.in the H. P. Foley A
- performing work as a qualified welder as of March '
I h
H. P. Foley procedure QCP-6 states in paragraph 6.4 that, "A f list of qualified welders and brazers shall be maintained by the Quality Control Department. The list shall be revised In paragraph 5.1, the whenever there is a change in status."
id procedure states that, " Welder qualification shall bee 6 months for welders for within the following time periods:
"C", "E",
qualified under Appendix "B", and "G"; or 3 monthsAppendix C o "I"."
for welders qualified under Appendix i procedure describes the steps necessary to qualify a welder to s
0-the AWS D1.1, Structural Welding Code, latest revision, forSuccessful c lding groove welds of unlimited thickness.this qualification test also q
' fillet welds on material of unlimited thickness.
~
QCP-5 further states in paragraph 5.1.1 that, "The Quality Control Department shall monitor each welder for each process qualified within the time period above to ensure that theThis welder's (s welder's qualifications do not lapse."
"JX") qualifications had effectively lapsed on January 27, 1983.
The failure to assure that welder qualification is t maintained in accordance with procedural and code requiremen s is considered an apparent item of noncompliance with 10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings." (50-275/83-13-02) (50-323/83-10-02)
,=
The concern was expressed that the final typed 8802-819, dated
' f. Concern:
version of Nonconformance Report (NCR) No.
March 4, 1983, varied substantially from the original rough This NCR documents a situation where, on l
draft of the NCR.
l March 2, 1983, H. P. Foley Quality Control Inspectors, left assigned to attend weld rod ovens in the Fuel Handling Building, On the site before assuring that all weld rod was returned.
this day (March 2, 1983), the site was evacuated due to
' inclement weather and deteriorating road conditions.
NRC Findings: This concern was not substantiated.
l To. address this concern, the inspectors examined the No.final typed 8802-819.
copy and earlier revisions of Nonconfermance Re j
l change in the sentence structure or wording which description of the nonconforming condition or of theDuring this e j recommended disposition.
l nonconformance report and related data, written 8802-1344, the inspector by a H. P.ncted that Inspection Report (IR) No.
a en
- 30 N Foley Quality Control Inspector on March 3, 1983, initially i documented the weld rod problem and provides a very descriptive explanation of the causeNeither of the nonconformance as well asnor the condition description a proposed disposition. .
the proposed disposition (as contained in Foley Inspection Report No. 8802-1344) varied substantially from the nonconformance report wording. The major difference was that the nonconformance report contained additional instructionsThe and actions to prevent recurrence of the identified problem.
documentation of Inspection Reports findings on Nonconformance [
- Reports is in accordance with Foley Quality Control Procedure No. QCP-3, Revision 5.0, " Processing and Control of Deviations and Nonconformances."
No items of noncompliance or deviations were identified.
in
- g. Concern: The concern was expressed or implied that, ,
general, nonconformance reports and their associated " Red Hold Tags" were not being properly controlled and processed.
NRC Findings: This concern was not substantiated.
~ The NRC inspec' tors performed a documentation examination of all of H. P. Foley's nonconformance reports, written in FebruaryFrom and March 1983, for the Fuel Handling Building modifications.
these nonconformance reports, approximately ten uncompleted reports were selected and the proper posting of the associated
[ D " Red Hold Tag" confirmed by locating the actual tags in the The inspectors also compared the rough drafts of all of field.
the above mentioned nonconformance reports to the final typed versions. This examination indicated that there were no significant changes between the initial drafts and the final versions of the reports, b-Subsequently, the inspectors examined the documentation and technical resolution of all of the above noted nonconformance reports.to determine if the resolutions appeared acceptable.
All resolutions were determined to be acceptable and I
technically adequate, except for one report, as detailed below.
t l Nonconformance Report No. 8833R-54, dated March 23, 1983 l
describes a situation where Nondestructive Examination of 1 fillet welds for structural steel connections in the Unit No.
i Fuel Handling Building identified number of weld discrepancies.
The type of weld discrepancies identified included cracks, linear indications, and undercut and involved 16 structural I
steel connections. The inspector notes that The section of the NCR l
each connection contains over 60 welds.
entitled " Disposition including means to prevent recurrence" l required the removal of the weld discrepancies in accordance
( with Foley's weld repair procedures, and contained the further l amplification, "To change the rod issue period to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to
((~'s prevent moisture pickup and/or add portable rod ovens antil the
,) rainy season ends." This disposition was approved and signed by the responsible licensee personnel.
The apparent implications of this type of weld discrepancy did
- (N not appear to be evaluated by the licensee or H. P. Foley for
(,,) -
generic consequences. Discussions with Foley quality supervision and engineers indicated that they would discuss this item with licensee construction and engineering personnel to determine whether the disposition was properly evaluated in ,
accordance with quality and regulatory requirements. This item is considered unresolved pending examination of the licensee's evaluation of this subject. (50-275/83-13-03 and 50-323/83-10-03)
- h. Concern: The concern was expressed or implied that, due to the large increase in construction personnel the quality of welding has degraded.
NRC Findings: This concern was substantiated in part.
The concern regarding welding quality has been addressed by routine NRC inspection reports that have identified procedural noncompliance (
Reference:
NRC Inspection Report Nos.
50-275/83-08 and 50-323/83-07) with regard to H. P. Foley welding activities. The noncompliances identified indicated a -~
problem with training and procedural adherence, both by the welders and Quality Control Inspectors. As a result of the NRC findings, the licensee has taken action to resolve the identified weld discrepancies by instituting a reinspection and training program, increased licensee surveillances of H. P.
Foley welding activities, and reorganization of H. P. Foley's
[T s- / Quality and Production Management. The issue of welding quality is further addressed in paragraph 5p of this report, in addition to the referenced NRC inspection reports.
No additional items of noncompliance or deviations were identified. ,1 -
- i. Concern: The concern was expressed or implied that the installation and routing of instrumentation tubing and electrical conduit and associated supports were performed r
without design drawings.
1 i
NRC Findings: The concern was substantiated in part, however, no safety concern was identified.
A review of .the installation program indicated that instrumentation tubing and electrical conduits were generally field routed. This procedure requires.that the craftsman route l
l the tubing and conduit per allowable pre-specified guidelines (slopes, curvature, joining locations, etc. through the "best" l
route available). This method was specified to accommodate l obstructions (hangers, re-bar and support installations, etc.)
that may exist in the field. A review of the programs utilized by the licensee for installation of supports and routing of l
-~ electrical conduit and instrumentation tubing is given below.
a l
From the dstart of by engineering i
Electrical Conduit Supports: construction, supports have (1) lled at PG&E's These General desigas have Office been formalized in controThese drawings in 3
. drawings Nos. 050029 and d June 7, 1971, 20,050030.
1969 an d -
were issued on January These drawings provide notes, symbols anWire S respectively. Therefore, typical details of Raceway haveandElectrical been Raceway S '
f the electrical conduit supports ibed above.appear tocontrolled an pre-established design details descr At the start of Instrumentation _ Tubing Supports: d without a formalized n engineering review (2) construction, installation occurreset On April 3, of controlled dra of each as-built installation was llation. per d drawing No. 049238 engineering personnel after insta tation supports and 1974, the licensee adopted a controlle which contained Also acceptable at thisinstrumen time, tionthe tubing licensee supports; required design methods.as-built drawings ofring allanalysis instrumentat was detailed in
,,, and for those supports 049238 that were an eng noinee bing controlled drawing No.After April with 3, 1974, instrumentation for compliance tu performed. nd design methods.
supports were built and inspectedthe drawing o Os was substantiated in part in that noh electrica Therefore, the concern However, this condition unique design drawing exists for eac ntrol measures were instrumentation tubing run or support.is acceptab .' -
and are implemented. r the Systems that failures in Additionally, the conduct t adversely ofimpact inspectionson peInter a non-safety related system will no This includes instrumentation that additional assurance of adjacent safety related systems. tubing and electrical c the acceptability of actual fie SIP Program. were identified.
No items of noncompliance or deviations h Quick was expressed or implied i that t eering Disposition Concern: The concern J. Fix Design Change (QFDC) procedure and Eng neality control Request (EDR) program are used to bypass qu functions.
NRC Findings: This concern was not substantiated.
mined that both of t
A review of the QFDC and EDR programs deters design k chang
(/ these programs are used for in-procesThese a problem programs are des clarifications. h on modifications in order that w en
\
l .
or there was a question on the engineering interpretation of a T -
design, the QFDC or EDR programs, respectively, could be used to obtain a response from engineering before quality control -
would be directed to perform their inspection.
The QFDC procedure draws its authority from PG&E's Procedure for Civil Structural Design Modification (No. CE-DC-5).
Section 3.6 of this procedure states that, " General Construction may as-built in accordance with their guidelines or obtain approval from the Onsite Project Engineering Group l With this authority, PG&E General l (OPEG) or Home Construction hasOffice."
required H. P. Fole<f to establish a procedure i
for the QFDC.
H. P. Foley Procedure QCP-17, Appendix This F, prescribes procedurethe requirements for the control of QFDC's.
describes how modifications of approved issued drawings are to be initiated. The intent of this procedure is to provide a system for controlling and approving design changes in a timely manner. This system may be used to address such things as f errors, omissions on drawings, interferences, simplification o work, in process work correction and drawing interpretation.
The system assures that any design changes, generated in accordance with the requirements and limitations of this procedure, are properly addressed.
Further, this procedure establishes that H. P. Foley Quality Control is to provide inspection and documentation of work performed in accordance with this procedure and otherTherefore, applicable procedures.
quality control inspection.
H. P. Foley Procedure (QCP-1) prescribes methods for the use of J.
Engineering Disposition Requests (EDR), The whic design and are sent to PG&E for evaluation and resolution.
responsible Resident Engineer for PG&E then prepares a H. P.
disposition and transmits the EDR back to H. P. Foley.
Foley uses the disposition to resolve the situation, and forthe work proceeds with the EDR attached to the work package clarification.
Therefore, the QFDC and the EDR program are controlled and do not by-pass quality control functions.
No items of noncompliance or deviation.s were identified.
I Concern:
The concern was expressed or implied that high ozone i
- k. levels in the Fuel Handling Building might impact on the quality of work in this area.
NRC Findings: The coacern was not substantiated.
Air quality in the Fuel Handling Building was identified This concern was as a .
potential problem in February 1983.
identified to CAL-OSHA who investigated the problem and measured not only ozone concentrations but also the levels of
= . . . - - , , . - . . - , . -
carbon monoxide, welding fumes, arsenic levels, and grinding p dust, in the Fuel Handling Building. The CAL-OSHA findings
\. indicated that there was'."no significant amount of ozone or carbon monoxide and thattthere were no employee overexposures".
These findings were confirmed by the NRC through telephone conversations with CAL-OSHA and are contained in CAL-OSHA report No. 54226 dated February 10, 1983. Therefore, there is no evidence to substantiate the concern that high levels of air pollution existed or resulted in deficient work.
No items of noncompliance or deviations were identified.
- 1. Concern: The concern was expressed or implied that excessive work hours were adversely affecting the quality control inspection effort.
NRC Findings: This concern was not substantiated.
An examination of tabulated work-hours for H. P. Foley Quality Control Inspectors and Supervisors, between December 7, 1982 and March 8, 1983, indicated that 90% of all Quality Control
~
Inspectors and Supervisors worked more than 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> a week during this period, with three inspectors working 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> a week or more. The relationship between excessive work-hours for Quality Control personnel and the effect on the quality of their inspection effort cannot be precisely established, though the NRC has previously identified problems with H. P.
. Foley's welding activities in the Fuel Handling Building
- (
Reference:
NRC Inspection Report No. 50-275/83-08 and paragraph Sp of this report). Excessive work hours are clearly undesirable, and discussions with licensee representatives indicated that actions have been taken to reduce the amount of l overtime. Licensee and contractor actions in this area will be assessed in the NRC followup to the notice of violation issued y.
in NRC Inspection Report No. 50-275/83-08.
No items of noncompliapce or deviations were identified.
- m. Cancern: The concern was expressed or implied that H. P.
~/oley's Quality Assurance / Quality Control organization was not independent.
NRC Findings: The concern was not substantiated.
10 CFR 50, Appendix B, Criterion I, " Organization", states, in part that, "That persons and organizations performing quality assurance functions shall have a sufficient authority and organizational freedom to identify quality problems; to initiate, recomrpand or provide solutions; and verify implementation of solutions. Such persons performing quality assurance functions shall report to a management level such O
- that this required authority and organizational freedom, l including sufficient independence from cost and schedule when opposed to safety considerations, are provided. Because of the -l many variables involved, such as the number of personnel, the type of activity being performed and the location or locations -
where activities are performed, the organizational structure for executing the quality assurance program may take various forms provided that the persons and organizations assigned the quality assurance functions have this required authority and organizational freedom. Irrespective of the organizational structure, the individual (s) assigned the responsibility for assuring effective execution of any portion of the quality assurance program at any location where activities subject to this Appendix are being performed shall have direct access to such levels of management as may be necessary to perform this function."
A review of the H. P. Fo'ey organization up to March 29, 1983, indicated that although the organization was structured such that Production and Quality Management reported to the H. P.
Foley Senior Project Manager, a dotted line (communication) relationship existed from the Quality Assurance Manager to a regional Vice President iW H. P. Foley's corporate offices in Martinez, California. Therefore, the H. P. Foley Company's organization met the requirements stated above in that access to high levels of management was available to the Quality O,s Department. Discussions with the Quality Assurance Manager
- indicated that he was aware of the availability of this option.
On March 29, 1983, a Quality Director position was created, which has responsibility for both Quality Assurance and Quality Control functions. The Quality Director and the Senior Project Manager now report to the newly created position of onsite Project Director. The dotted line (communication) relationship from the Quality Director to the regional Vice-President in l. .
Martinez, California is an option still available to the Quality Department.
- a No items of noncompliance or deviations were identified.
- n. Concern: The concern was expressed or implied that material from Bostrom-Bergen Company was received without the necessary documentation.
NRC Findings: The concern was substantiated, however this item was the subject of previous NRC enforcement action (
Reference:
NRC Inspection Report No. 50-323/82-09) and corrective action ,
has been verified by the NRC (
Reference:
NRC Inspection Report No. 80-323/82-13).
On December 14, 1981 an allegation concerning acceptance of Bostrom-Bergen supplied material by the H. P. Foley Company, without the proper documentation was received by the NRC.
L l
pd Subsequent investigation of this allegation (see NRC Inspection Reports Nos. 50-323/82-06, 82-08 and 82-09) resulted in the g
II - -- . - -
. j l
issuance of an item of noncompliance on June 14, 1982, documenting the failure of H. P. Foley to follow quality
- procedures in the processing of nonconforming material. In response to the item of noncompliance, the licensee directed the contractor to perform a 100% audit of all Class I purchase orders dating back to 1978, to revise the contractor's .
procedures to ensure that proper controls exist for controlling of nonconforming material until receipt of proper documentation, and to conduct training sessions for personnel in regard to these procedure changes. As documented in NRC Inspection Report No. 50-323/82-13, the NRC inspector verified implementation of the licensee's specified corrective actions and concluded that ths licensee's actions were proper and satis fa ctory.
No additional items of noncompliance or deviations were identified.
- o. Concern: The concern was expressed or implied that water had been seen in and around buried electrical conouits in the intake structure.
~
NRC Findings: The concern was substantiated in part. However, as a result of problems identified by the licensee on February 29, 1980 the licensee has taken action to divert, control, and minimize water damage to those conduits.
I) - On February 29, 1980 a potentially reportable deficiency was
' reported to the NRC, (
Reference:
PG&E Nonconformance Report j No. DCI-80-RE-003) wherein the licensee identified the insulation failure of a number of electrical conductors routed to the Unit 1 intake structure. These insulation failures apparently occurred as a result of damage to, or breakage of, the buried conduits carrying the conductors. This deficiency,
- if left uncorrected, would have affected the operation of t safety-related Auxiliary Salt Water System equipment for Unit 1 located in the intake structure. As a result, PG&E directed l
that electrical conduits and cables be repaired, with the conduits run in a concrete envelope on top of a concrete leveling pad. In addition, concrete dikes were installed to divert and control water, and the design of the concrete envelope was reviewed by soil consultants for seismic considerations. It has been determined that since that period no failures of insulation or circuits have been identified in that area of the intake structure.
No items of noncompliance or deviations were identified.
- p. Concern: The concern was expressed or implied that the quality of weld!ng was net adequate in the Fuel Handling Building. In addition, it was alleged that 80% of all nonconformances were l
being identified in the Fuel Handling Building.
1 O)
C_
s NRC Findings: This concern was substantiated, in part. As a result of NRC inspection from February 28 to March 4, 1983 l
l
a number of (Report Nos. 50-275/83-08 and 50-323/83-07) -
problems regarding Fuel Handling Building (FHB) welding wereIn response, th
'r'~T identified and a notice of violation issued.
( ,) licensee instituted a program to reinspect 10% of the recent Fuel Handling Building welding, the findings of whichPreliminary results subsequently led to a 100% reinspection.
of this reinspection indicate that about 2% of the FHB welds. f -
require added filler metal and another 8% require grinding o weld metal.
This general concern will be followed and considered in the licensee's response to the Notice of Violation and during subsequent inspections.
In o'rder to determine whether the concern regarding the high percentage of nonconformances in the Fuel Handling Building was accurate, the inspectors examined all nonconformances written during the month of February. This examination determined that the percentage of nonconformance reports concerning identified problems in the Fuel Handling Building, ll versus total number of nonconformance reports written on a H. P. Foley construction activities,Therefore, wasthis approximately portion of the45% (as opposed to the alleged 80%). However, the quality of concern could not be substantiated. known
~ the welding activities in the Fuel Handling Building is a item of concern to the NRC and will be continue to receive above average inspection effort.
No items of noncompliance or deviations were identified.
fO The concern was expressed or implied that prior to V q. Concern:
1974, there was no formal Quality Assurance Program, no nonconformance reports (NCRs) written, and a weakness l existed in Quality Control functions (no inspection of too calibration, electrical raceways, weld rod control, welding l-procedure and material receipt).
NRC Findings: This concern was not substantiated.
TheinshectorexaminedthequalityprogramsforH.P.Foley The inspector's examination determined that, prior to 1974.for each contract awarded to H. P. Foley by PG&E, there e a Quality Assurance Manual and implementing Quality procedures.
programs follows:
The first contract specification awarded H. P. Foley wasThis basic e 1 The specification Number 8807. specification was approved by PG j quality program for this specification addressed:
l I'
1)
Receipt, storage, handling, and inspection of electrical equipment, conduit, and wire.
conduit, cable
' 2) Installation of electrical equipment, f-'s trays, wire and grounding.
( ,)
l l
t, 1
.fm 3) Document control and drawing control
. 4) Control of test instrumentation equipment and tools
- 5) Quality Assurance Organization and qualification of -
personnel
- 6) Maintenance of installed equipment
- 7) Discrepancy reports and reject tags (predecessor to NCR and hold tags)
Welding o'r weld rod control was not addressed in this procedure until January 1974. The reason that no welding or veld rod control procedures existed, during this period, was that H. P.
Foley was not required by contract (Contract No. 8807) to perform welding. When H. P. Foley was awarded cleanup Contract Specification Number 8771 (in January 1974), welding and weld rod control requirements were included in both Contract No. 8807 and Contract No. 8771.
Prior to 1974, H. P. Foley had one additional contract with PG&E
~
(specification No. 8802). This contract was for small -
electrical components, raceway, and instrumentation installation and was approved by PG&E on August 8, 1972. This specification included a Quality Assurance Manual and implementing quality control procedures addressing:
b .
- 1) Receipt, handling, storage, installation and maintenance of electrical equipment, cable trays and conduits
- 2) Wire pulling, testing and termination
- 3) Document and drawing control 3
- 4) Test instruments and control l
- 5) Calibration of test instruments.
No welding or weld control was required by this specification.
i Additionally, the inspector noted that a Discrepancy Report process was in effect at the time and served the same function as the current NCR process. Therefore, the Quality Assurance Manual and l
Quality Control procedures did include provisions contrary to each of the expressed or implied concerns.
No items of noncompliance or deviations were identified.
O l
l
- r. Concern: The concern was expressed or implied that the " mirror image" concept used in the construction of Unit No. I and Unit No. 2 was confusing and resulted in excessive craft errors. >
NRC Findings: This concern was not substantiated. However, it should be recognized that the " mirror image" concern did
^
contribute to the design problem that resulted in the suspension of the Unit No. I fuel load / low power test license
! in November 1981. This subject is being addressed in a comprehensive program for the reverification of the plant design i and is outside the scope of this special inspection.
j In addre , sing the concern that the " mirror image" concept caused confusion and craft errors during the installation of equipment and systems in the field, the inspectors interviewed H. P. Foley Company production and quality control personnel to determine their impressions of this concern. None of the individuals interviewed indicated that this concern was valid.
No items of noncompliance or deviations were identified.
. s. Concern: The concern was expressed that.the
'nspector-to-worker ratio was inadequate prior to 1974.
i i NRC Findings: The concern was not substantiated.
l An examination of the H. P. Foley organization and Quality
! Assurance / Quality Control manpower levels prior to June 4, 1974 indicated that there were 23 persons involved in quality assurance / quality control functions during this period. The l
organization consisted of four supervisors, fifteen l
inspectors, and four clerks. According to the former H. P.
Foley Company employees (
Reference:
State of California transcript, page 23) in 1973 the H. P. Foley Quality b Department consisted of, "A manager, assistant manager, and two or three inspectors." Based on the findings of the NRC inspectors as noted above, this portion of the concern could not i be substantiated.
The testimony of the two former H. P. Foley employees further indicates that craft personnel during this period totaled, "two or three hundred electricians." Using these numbers, the inspector-to-craft ratio (using 19 inspectors to 300 craft workers) would be 1:16. Interviews conducted with H. P. Foley management indicated the inspector to craft ratio actually varied anywhere.from 1:10 to 1:20 during this period because of varying workload and the fact that Quality Control Inspectors only examined Class I work, as opposed to Class II work which received no quality control inspection. Class II identifies structures, systems and components which are not nuclear safety related.
Although the NRC has no regulations regarding appropriate ratios of Quality Assurance / Quality Control inspectors to craft
- ~ , . . - . - .- - - .. - _ - - . _ - - _ _ _ - - =
i personnel, the NRC did perform a nationwide survey on this subject in June 1981. The survey results were inconclusive.
The ratio of inspector to craft varied anywhere from 1:1.7 (WNP-2) to 1:26 (Palo Verde). In addition to the contractor QA/QC organizations, the licensee maintains their own QA/QC i
organization which provides for surveillance and audit of contractor activities. Furthermore, the licensee maintains a -
staff of personnel, assigned to each of the Resident Electrical, Mechanical, Civil and Startup Engineers, who also provide for inspection and overview of the' work performed by site contractors. These personnel further increase the inspector / craft ratio.
The inspector considers that a substantial conclusion regarding the adequacy of the inspector-to-craft ratio at Diablo Canyon during this period cannot be established with certainty.
1 i
No items of noncompliance or deviations were identified.
- 6. Additional NRC Inspections During the course of interviewing individuals referenced in the testimony of the former Quality Control Manager and the Assistant Quality Control Manager, the NRC inspectors became concerned that methods used by the H. P. Foley Company for recertifying welder or welding operators might not meet the intent of the ASME Code. This
. report identifies a similar problem wherein a welder was not recertified within the time limits specified by the AWS Code, as 1
( well as, contractor procedural requirements. This item is the subject of NRC enforcement action and is addressed in paragraph Se of this report. This new NRC concern deals with the methods employed by H. P. Foley to recertify welders or welding operators.
The 1980 Edition of ASME Boiler and Pressure Vessel coa ,Section IX, " Welding and Brazing", Subarticle QW-322, " Renewal of Qualifications", states thap, " Renewal of qualification of a ,
performance qualification is required: (a) when a welder or welding operator has not used the specific process, i.e., metal-arc, gas,
- submerged arc, etc. , for a period of three months or more; except when employed on some other welding process, the period may be extended to six months; or (b) when there is a specific reason to i question his ability to make welds that meet the specification.
Renewal of qualification for a specific welding process under (a) above may be made in only a single test joint (plate or pipe) on any thickness, position, or material to re-establish the welder's or '
welding operator's qualification for any thickness, position, or material for which he was prevously qualified."
A review of forty H. P. Foley welder certifications determined that all welders were certified or recertified in accordance with H. P.
Foley's Quality Control Procedure, QCP-5 " Welder and Brazer Qualifications and the Qualification of Welding and Brazing Procedures." However, the inspector noted that one welder, (symbol
't
- , , ___,r, . ~ . . , _ . , _ , - . , _ _ , _
2i- .
]
S-4, recertified on February 19, 1983, to an ASME Welding Procedure Specification (WPS) No. H-03, a Gas Tungsten Arc Welding (GTAW) process), apparently wasirecertified by having the welder strike an arc with the nonconsumable tungsten electrode long enough for the H. P. Foley Quality Control Inspector to take amperage and voltage readings and record these readings on an In-Process Welding -
Inspection Report. The report also indicates that no weld rod was issued during this time. The signature of the Quality Control Inspector on the In-Process Welding Inspection Report apparently 4 accepts the recertification of the welder to the particular welding process. This particular velder was found to be on the H. P. Foley Active Welderr List, dated April 27, 1983. The NRC inspectors are l
aware that this particular individual did not perform welding after this certification. A review of employer payroll and weld rod withdrawal records indicated that this welder had been promoted to l
Foreman on January 18, 1983 and had not performed welding since that date. However, it is of concern that he had been placed on the Active Welder's List and was considered ready and able to perform welding based on the re-certification of February 19, 1983.
For those welders that were re-certified and had not used a welding process for 3 months or more, the inspectors observed that the In-Process Welding Inspection Report fails to indicate whether the i
welders were recertified by making a test joint (on a plate or pipe) or by in-process welding in accordance with the Code. Thus, the inspector is concerned that the discrepant welder requalification process described above, may have been used to recertify welders O - currently appearing on the Active Welders List.
It appears that measures were not established to assure that recertification of welders was accomplished in accordance with the Code and the requirements of 10 CFR 50, Appendix B, Criteria IX,
" Control of Special Processes". This is an apparent item of ;
noncompliance (50-275/83-13-04 and 50-323/83-10-04).
l l 7. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, or items of noncompliance, or deviations. An unresolved item was identified during this inspection and is discussed in paragraph Sg of this report.
e r
I t
l '
-z2-
- - s 8. Exit Interview I -
During the course of the special inspection, the inspectors had '
numerous discussions with licensee and Foley personnel determine whether or not the concerns were substantiated. On April 6, 1983, the inspectors met with the licensee's Project Superintendent and A '
discussed the findings of the special inspection at that point.
final discussion was held on May 12, 1983 wherein the three items of noncompliance (see Appendix A to the cover letter)~and the one unresolved item were identified. As noted in the above, the majority of the concerns were not substantiated. However a number of noncompliances were identified, which, coupled with previously noted problems with this contractor and other noted items (high overtime for QC personnel, greatly accelerated hiring and construction rates) give us cause for concern. Accordingly, additional licensee management actions are warranted. The NRC will evaluate the effectiveness of actions taken following receipt of the licensee's response to the Notice of Violation and the additional requested information.
O .
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O ATTACHMENT 3 Preliminary Draft of INDEPENDENT DESIGN VERIFICATION PROGRAM INTERIM TECHNICAL REPORT NO. 36, REVISION NO. 1
" FINAL REPORT ON CONSTRUCTION QUALITY ASSURANCE EVALUATION OF GUY F. ATKINSON COMPANY PERFORMED BY STONE & WEBSTER ENGINEERING COMPANY" O
Provided to Atomic Safety and Licensing Appeal Board (Under Separate Cover)
- and provided to the Parties by the Independent Design
! Verification Program.
I O
O ATTACHMENT 4 i ,
Preliminary Draft of INDEPENDENT DESIGN VERIFICATION PROGRAM INTERIM TECHNICAL REPORT i
NO. 38, REVISION NO. 2
" FINAL REPORT ON CONSTRUCTION QUALITY ASSURANCE EVALUATION OF WISMER & BECKER PERFORMED BY STONE & WEBSTER ENGINEERING CORPORATION" O
Provided to Atomic Safety and Licensing Appeal Board (Under Separate Cover) 4 and provided to the Parties by the Independent Design Verification Program.
- l l
i i
ATTACHMENT 5 i
i i
i i
TRANSCRIPT OF THE MAY 21, 1983 MEETING l
j CONCERNING THE DISCUSSION I OF IDVP AUDIT j OF DCNPP-1 CONSTRUCTION
! QUALITY ASSURANCE i
4 l
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O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
l In the matter of:
DIABLO CANYON Docket No. 50-275 '
DISCUSSION OF IDVP AUDIT OF DCNPP-1 CONSTRUCTION QUALITY ASSURANCE V)
Location: Boston, Massachusetts Pages: 1 - 90 Date: Saturday, 21 May 1983 TAYLOE ASSOCIATES coun Repen=
ses i suwt, N.W. Suite feed Washimsica, D.C. 30006 (202) 293-3M0
e i
0 1
1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3
DISCUSSION OF IDVP AUDIT OF DCNPP-1 4
CONSTRUCTION QUALITY ASSURANCE 5
6 Conference Room 321 Logan Hilton Hotel 7 Logan Airport Boston, Massachusetts 8
Saturday, May 21, 1993 9
10 The NRC-IDVP meeting convened, pursuant to 1
! 11 notice, at 9:30 a.m.
t O' 12 NRC Staff Present:
13 H. SCHIERLING, Presiding 14 J. SPRAUL L. CHANDLER 15 T. BISHOP 16 Teledyne Staff Present:
17 J. CRAGIN I
18 J. FLAHERTY l W. COOPER i 19 L. NORIEGA 20 Stone and Webster Staff Present:
j 21 F. SESTAK 22 C. LUNDIN
- 5. BARANOW 23 C. RICHARDSON E. ERLANDSON 24 D. IVES F. BEARHAM O 25 TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006
. _. _ _ _ . - = __ _ __ - - - _ _ - _ ~ _ _ _ ._ -__ . __ - _. - - - - . - _ _ .
i i 1 2
1 PG&E Staff Present:
2 B. NORTON 3 S. SKIDMORE J. MANNING 4 R. ETZLER R/ TWIDDY 5
i 6 Bechtel Staff Present:
I i 7 C. DICK
! H. FRIEND 8 P. MASON 9 Westinghouse Staff Present: ,
10 W. GAUGLOFF D. ALEXANDER 11 On Behalf of the State ' of California:
O 12 13 R. HUBBARD 14 15 t
i 16 17 18 19 20 21 22 23 j 24 25 i TAYLOE ASSOCIATES I 1625 I Street, N.W. - Suite 1904 l Washington, D.C. 20006
T O 3 1 PROCEED I NGS 2 MR. SCHIERLING: Good morning.
3 My name is Hans Sch1erling. I am with the NRC.
4 We meet here together today for a meeting to discuss 5 construction quality assurance.
6 In ettendance are representatives from 7 Teledyne, from Stone and Webster and PG&E. Represented 8 also 1s the State of California.
9 Before we bes1n with our Introduction of the 10 members here, I would you to be aware we are taking a 11 transcript of this meeting and for that purpose we shculc
() 12 13 lim 1t ourselves to have only'one person talk at a time and please speak clearly so we have a good transcript 14 available.
15 Why don't we start with the introduction.
16 Jack, why don't you go ahead.
17 MR. SPRAUL: My name is Jack Spraul. I am with 18 the NRC Office of Inspection and Enforcement, QLality l 19 Assurance Branch.
l l 20 MR. CHANDLER: I am Lawrence Chandler. I am with 21 the Office of Executive Legal Director and I am counsel to 22 the staff on the Diablo Canyon.
23 MR. BISHOP: My name is Tom Bishop. I am Chief 24 of the Reactor Projects Branch in Region V of the NRC.
O
\ 1 25 MR. HUBBARD: My name is Richard Hubbard. I am ud l
l TAYLNE ASSOCIATES 1625 I Street, N.W. - Suite 1904 i Mnnhnn h F0nRn T"%
~
I 1 representing the State of California.
2 MR. FLAHERTY: Jim Flaherty. Teledyne 3 Engineering Services.
4 MR. ERLANDSON: Ed Erlandson, Deputy Director of 5 Construction, Stone and Webster, 6 MR. RICHARDSON: Carl Richardson, Engineering 7 Manager, Stone and Webster.
8 MR. BARANOW: Stan Baranow, Assistant Deputy 9 Senior Manager, Stone and Webster.
10 MR. LUNDIN: Craig Lundin, Chief Engineer, 11 Quality Assistance Division, Stone and Webster.
l
() 12 13 MR. SISTAK:
Stone and Webster, IDVP.
Franh Sistak, Project Manager, 14 MR. IVES: Richard Ives, SDQA Engineering, Stone 15 and Webster.
16 MR. COOPER: Philip Cooper, TES Program Manager.
17 MR. NORIEGA: Leandro Noriega, Senior Engineer, 19 TES.
19 MR. MASON: I am Peter Mason, the Diablo Canyon 20 Project, Bechtel.
21 MR. CRAGIN: John Cragin, Teledyne Engineering 22 Services.
23 MR. TWIDDY: Dick Twiddy, PG&G Quality Assurance 1
24 Supervisor, Diablo Canyon.
() 25 MR. ETILER: Rick Etzler, Project l
TAYLNE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Mmhanatona D.C. D6
a x
5 1 Superintendent, Diablo Canyon.
2 MR. MANNING: Jim Manning, Construction 3 Superintendent, Diablo Canyon Project.
4 MR. BEARHAM: Fred Bearham, Quality Assurance 5 Engineer, Stone and Webster.
6 MR. FRIEND: Howard Friend, Project Manager.
7 Diablo Canyon, the Diablo Canyon Project.
O MR. NORTON: Bruce Norton, Attorney for PG&E.
9 MR. SKIDMORE: Steve Skidmore, Manager of 10 Quality Assurance, PG&E.
11 MR. DICK: Charles Dick, Diablo Canyon Project
() 12 Managment.
MR. SCHIERLING:
Pete, do we have you in there?
13 14 MR. MASON: Yes, sir.
15 MR. SCHIERLING: Okay.
16 The purpose of the meeting, as I mentioned 17 earlier, is to discuss certain aspects of construction 18 quality assurance.
19 As you are aware, the Diablo Canyon project has 20 through Teledyne and Stone and Webster conducted an audit 21 or construction quality assurance efforts that were in 22 place prior during the construction of the Diablo Canyon 23 plan.
24 That effort has been completed. It was 25 primarily conducted by Stone and Webster. The effort has TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 M
6 f'
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1 been completed. Two interim technical reports have been 2 issued, ITR-36 and ITR-38, which exist in Revision 0 and 3 Revision 1. The staff has reviewed both of those reports.
4 We recently have requested the IDVP to provide some 5 additional information regarding the activities.
6 In general we are interested in two aspects.
7 One is we would like to obtain some more information 8 regarding the close-out of specific EOIs identified in 9 both reports and, secondly, we would like the IDVP to 10 address the bases for the general statements in the report 11 regarding the adequacy of the quality assurance that was 12 applied and that existed and'was implemented for the two 13 companies that were audited.
14 We might have some additional specific 15 questions as we go along, but I understand that you have 16 Prepared a presentation and I think it might be best to 17 get everybody up to speed and on the common denominator to 18 go through that presentation hopefully without any 19 interruption.
20 Bill, I turn it over to you.
21 MR. COOPER: Thank you, Hans, and good morning, 22 gentlemen and the lady who is present, and welcome to 23 Boston.
24 (Laughter.)
/~'\ 65
' MR. COOPER: My role this morning is a brief (s,/
l l
l TAYLOE ASSOCIATES
! 1625 I Street, N.W. - Suite 1904 L
Washington, D.C. 29906
. 7 1
introduction of the status of the construction QA effort.
2 In a quick summary of the background, the first 3 introduction of this into the system was on September 1st 4 at a meeting between staff and the Diablo Canyon project 5 where Mr. Maneatis of PG&E announced that they were 6 volunteering to have such a program. This was confirmed by 7 the PG&E letter of September 7th.
8 During the next few weeks Mr. Maneatis and Mr.
9 Friend came and visited with me and talked about their 10 expectations from this program, their plans for it, the 11 interest in having the IDVP operate the program in the l
/N 12 same manner that we had the Pest of it from the viewpoint
\ss/
13 of independence and our procedures.
14 The three of us and others met with the senior 15 Stone and Webster personnel in engineering, construction 16 and quality assurance and I may have missed one area, and 17 if I did, I am sorry, but to indicate the level of gg interest and the level of effort which the utility wanted us to operate in in this manner.
Based upon those discussions, the IDVP defined i
an adjunct program for evaluation of CQA and we submitted
- 21 this program, or Revision 1 of this program on October 5th l
i of 1982.
l 23 Very briefly, that program established that two
(' s organizations would be audited and established four tasks.
TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1984 t W Thanaesna D.c. O
8 O
one on QA program, another un' construction verification, a third on processing of the findings and a fourth on reporting.
3 The reporting system used the normal ITR system 4
1 the independent program and a modified EOI system, and 5
I think it is very important to understand that the EDI system used was different here than elsewhere. Our 7
8 We defined the Class A error as being a 9
finding, something which was accurate in potential for g
significant impact on adequacy.
A We defined in thesEOI system a Class C error as U something that in the QA world would be termed an
\
g observation, that the potential finding wa s -accu r a t e but g
it did not have a potential for s1gnificant impact on adequacy.
g The third category was that the potqntialu finding was invalid. -
g g
We reported these results i n 'I TR-3 6 and 3C. 36I ,
applied to Wismer-Becker. There was one finding, ,19 s g observations and five were invalid. k.
ITR-38 reported on Guy F. Atkinson. There there> ,- U 2., s, g were four observations. Mr. Novak of staff in his letter to me of May 2nd raised the issues which Hans has 3
summarized very well as to their concerns about the ITRs.
25 I
I TAYLOE ASSOCIATES )
1625 I Street, N.W. - Suite 1004 MonMgWhJhFnf2RQh
e m 9 I
a First, that the information in the ITR they did not consider was sufficient to justify closing out the EOIs and, second, the review results did not appear to be entirely consistent with specific EOI findings.
I response to that letter, the IDVP had 5
prepared revisions to both ITRs in what we thought was responsive to both of these issues, 7
A staff phone call of the 17th of this month g
indicated very clearly that we had not fully understood 9
2 their concern in this second area, and it is as a result of that phone call that we are having this meeting here this morning in an attempt'to provide further discussion g on'these matters.
'The Stone and Webster folks have prepared a
~
g ,
very appropriate presentation which will introduce the issues in a time of approximately a half an hour.
1 x _
- s g FolicJtng that we are prepared to go into whatever detail
- ~s '
- O. you Nish, b d '. I' wo u l d suggest that since certain aspects 18 <
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- . i ,,
of the' intent and t'h eh p r o c e d u r e s of this program have not J ' - 19 l
,,0 4
Deen fdliy'uAdeystood,k'that it would be desirable to let 3s \
them go throu3h that point.
21
\1
- L e t en e ask first if there are any questions and, if not, I will turn it over to Frank Sestah from g
E , Stone an? Webster.
,,1,a 24 ,
h,Txh . ,h w Frank, why don't you go ahead.
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ys, ; dYLOE ASSOCIATES I- t, N\ ' 1 25 I,'Itreet, N.W. - Suite 1904
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P2ThMn9FB1th.LD. __ ___ _
10 MR. SESTAK: Thank you. I am Frank Sestak.
' JThe construction QA review and audit was 2
intended to assess whether the construction of Diablo 3
Canyon Nuclear Power Planti Unit 1i was performed in 4
3 accord,ance with the quality requirements appropriate for the t i w.e . o f plant construction.
i
,, ,The program was accomplished by the development 7
! 'c ,
of check lists of attributes for two contractors based on 3, a requirements from various documents such as PG&E 9
specifications, contractor or subcontractor QA programs, g PG&E drawinns and cc tractor.'and subcontractor drawings,
/ 'A Finding and Review Committee was established g to r'eview each potential finding developed by field auditors and inspectors for determination and accuracy and g
assess its impact on the adequacy of the plant.
5 The FRC was made up of five senior experienced personnel as follows:
g Ed Erlandson, Deputy Director of Construction, g ,
with greater than.35 years experience in construction and 9
construction manager and superintendent at a number of g
nucle r plantsi g ,
! Carl Richardson Engineering Manager with l
g greater than 20 years experience in power projectsi project manager and projact engineer on nuclear plantsi 3
Craig Lundin, Stone and Webster, Chief TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1804
_ _ _ _ _ , Washington . D.C. 20006_
. l 11 Engineer, Quality Assistance Division with greater than 15 years experience in QA and site QC managkr at a number of 2
nuclear plantsi 3
Jim Flaherty, Teledyne, Manager of Engineering, Design and Testing with 15 years experience in the nuclear 5
fieldi and Frank Sustak, that is me, Chief Engineer of the 7
e n g ea e an years ex er ence in 8
power projects, project engineer on various nuclear 9
Projects, Project Manager of the Stone and Webster IDVP effort and Chairman of the FRC.
Each potential fioding report 1orwarded to the FRC was reviewed and classified per IDVP program g
requirements. As Bill alluded to before, they were categorized as findings, observations and invalid.
Upon completiog of all FRC reviews, 29 in total, the FRC conducted a site visit on November 16th and g
17th. During this site inspection each PFR was visually B
reviewed by one or more members of the FRC.
g Upon receipt of the PG&E response to the PFRs, 29 EOIs were classified and categorized as follows: One was a finding, five were invalid and 23 were observations, g The observations were further broken down into 10 programmatic and 13 other.
During the course of our program today we hope 5
TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 M T Gfirne Q mao R(L D
4 12 1 to answer many of the questions raised in various and 2 recent documents such as the NRC letter to TES, 3 Novak/ Cooper of 5/2/83, and a recent joint intervenor 4 petition of 5/10 and 5/17.
5 At the conclusion of our program, we will be 6 open to questions and comments.
7 If there are no questions, we will proceed with 8 our presentation.
9 MR. CHANDLER: Frank, let me just make one 10 comment on something you just said, and that is I guess 11 the staff's principal concern at this meeting is with 12 respect to the matters outlined in Mr. Novak's letter of
[~/
)
13 May 2.
14 MR. SESTAK: We hope to touch on those.
15 MR. CHANDLER: Okay.
16 MR. SESTAK: Frank Lundin, the gentleman sitting
( 17 next to me, will begin with a review of the various check 18 lists developed for each contractor by the site QA team 19 and where approprite identify areas related to criteria in 20 10 CFR 50, Appendix B.
21 He will also review in detail the documents 22 related to EOI 90-26, which was a finding, and two other 23 EOIs which were classified as observations.
24 I hope we answer many of your questions
() 25 relating to the various documents.
l TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1804 Washington, D.C. 20006
13 U
1 If there are no questions, we will proceed with 2 Craig.
3 MR. FRIEND: Excuse me, I do have a question. I 4 think I would like to direct it to yourself and to Bill 5 Cooper, and I guess the question is the following.
6 Was it the intent to have the ITRs as a general 7 category be self-standing and answer all the possible 8 questions and allow the reader to reach a total resolution 9 in accordance with the IDVP's resolution as part of the 10 ITR?
11 MR. COOPER: No, sir, it was not, and our 12 procedures permit requests for clarification from all
(
13 parties and we had received none up to the May 2nd letter.
14 MR. FRIEND: Thank you.
15 MR. SESTAK: Craig.
16 MR. LUNDIN: I am Craig Lundin. As Frank 17 mentioned, we were to review the two contractors to assure 18 that the elements of the quality assurance program were 19 present for cctstruction at that period of timei as well 20 as to verify as much as could be done the 1mplementation 21 of that quality assurance program.
22 In doing that we developed check lists to work 23 to. Four check lists were developed and utilized by the 24 team at the site. Two were verification check lists for
) 25 actual inspection performed and two were assessment plans TAYLGE ASSOCIATES 1625 I Street, N.W. - Suite 1904 MorGfen2Egtp %(L PETM
F 14 1 to determine if the practices were in compliance with the 2 specifications and that they had a quality assurance 3 program in existence.
4 In development of these check lists, the 5 specifications we used, the quality assurance programs we 6 used and other documents that would be appropriate to make 7 this verification, the attributes developed can be 8 associated with the elements of a quality assurance 9 program as delineated in 10 CFR 50, Appendix B in that 10 they were appropriate for the scope of the contractor and 11 asked the appropriate questions to assure those functions
() 12 such as inspection, training material control and other 13 appropriate criteria that should have been applied.
14 They were not cross-referenced specifically to 15 those. However, they do relate in that we did assure that 16 the elements of that QA program were in existence for that 17 contractor scope of work.
18 In processing the findings, these check lists, 19 if I may digress, these check lists have been available 20 for audit and they have been completed by the team.
21 Subsequently they wrote potential finding reports and 22 submitted them to the committee. They were processed and 23 they are still available.
24 In processing the findings, the other aspect 25 that I wanted to touch upon in File No. 9026 was to use it TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904
O 15 1 as an example of how the committee processed the findings.
2 I brought three as examples that I could talk 3 from, but 9026 being the finding, the only Class A, it 4 would probably be most appropriate.
5 The initial report which came from the field 6 reported that further specifications, an LP examination of 1
7 the lug removal areas on the loop piping, that t6are was i
8 no record of it having been performed.
9 MR. SCHIERLING: Craig, could you put in maybe 10 what time frame we are talking about, when was the work i 11 done, the actual construction work?
() 12 13 MR. LUNDIN:
particular scope of work.
Approximately 1973 in this Someone can correct me on that, 14 but in that time frame.
15 MR. SCHIERLING: The records you looked at were 16 also appropriate for that time frame?
17 MR. LUNDIN: That is correct. The records were 18 available and complete and we found no evidence of this 19 particular inspection having been performed as required.
20 We processed our open item report in that evaluated that 21 there was no documentation available and we issued it as 22 that.
23 We did receive a response in which we were told 24 that PG&E had contracted with Pullman to perform this work
() 25 because their review had not turned up the records that it TAYLOE ASSOCIATES l 1625 I Street, N.W. - Suite 1904 6
16 1 had been performed. So that package for Pullman's work was 2 complete 1y done prior to it being presented to Stone and 3 Webster for review.
4 That package was sent to us and it showed where 5 all the lug removal areas had been performed by Pullman.
6 It included information to show that Pullman had been 7 approved by PG&E and they were utilizing their QA program.
8 We reviewed the documentation and with one 9 exception Pullman had documented the acceptability of the 10 lug removal areas. In that particular case, Pullman in l
11 working to their procedures had rejected an indication.
[~ 12 They turned it over to PG&Ew'ho had performed another V) 13 examination under their own procedures and accepted that 14 liquid penetrant exam.
15 The Findings Review Committee determined that 16 for our independence that we required that this liquid 17 penetrant test be performed by a third party which would l 18 be Stone and Webster and witnessed by a member of the 19 Findings Review Committee to assure the compliance with 20 all the information that we had in the package.
l l 21 That was done and that information in that l
22 review and the required inspection was brought back to the l
23 committee and the committee acted on the fact that, on 24 that one particular instance, that the liquid penetrant 25 exam that had been performed by PG&E was accurate and
(
TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20906
17 1 acceptable. In fact, the indication was within the 2 requirements that could be accepted per the Code as well 3 as the in-service inspection requirements of PG&E.
4 MR. SPRAUL: Craig, pardon me, when was this 5 Pullman work done?
6 MR. SESTAK: Late '82.
7 MR. LUNDIN: I think most of it was performed 8 actually in January of '82.
9 MR. SPRAUL: Fine, thank you.
10 MR. LUNDIN: That particular review that
!* Pullman did, which I did not go into, included sketches of 12 all the loops and the surge line I believe as well and the
[
13 pump casings and showed all areas of lugs per the drawings 14 and LP reports, thickness reports where required for all 15 those areas. This is in addition, of course, to our review 16 which had performed a visual inspection on all four loops l 17 in the surge line piping.
18 The Findings Review Committee in closing this 19 item, this file, or recommending closure, viewed the 20 information supplied by Pullman and the other information 21 we independently reviewed to assure that the specification 22 requirements were met in determining that the file was
(
l l 23 adequate for closure. This particular example was 24 classified as an eight.
We utilized this type of process on all the
( 25 TAYLGE ASSOCIATES 1625 I Street, N.W. - Suite 1994
.-_._W ashington, D.C. 20006 . . _ _ _ _ __ _ _ _ . _ _
i 4
'h 18 1 potential findings which were presented to the committee 2 where we determined its accuracy, got any information we 3 needed from the team to make that determination and we 4 presented it to the Program Manager. We reviewed any 5 information that was returned to us by PG&E to clarify or 6 add to what we might know at that point in time.
7 We utilized any consulting information we 8 needed for our own engineering departments as independent 9 to review any of the technical information that was 10 provided and made our judgments based on all that i 11 information. The review of each one of these is part of i
(~ 12 the project filed report.
b} 13 I will clarify a point that I mentioned earlier 14 in that why the review was performed by PG&E on one of the 15 indications found by Pullman.
16 Pullman was hired to do this work from the 17 documents that we were shown, the purchase order, to work 18 to their own procedure. Their own procedure had a maximum 19 indication size that they could accept. In working to 20 their procedures, the indication was unacceptable to their 21 procedure. Although it was found to be acceptable to the 22 actual code, their procedure would not allow acceptance of 23 that. That is why that one item was different than the 24 other indications found and resolved.by Pullman. As a 25 result of that information we performed a third party, if TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004 Washington, D.C. 20006
19 1 you will, to assure that that process was complete.
2 Are there any questions?
3 MR. SCHIERLING: Yes. Somehow I do not quite 4 understand. We are talking about work that was performed 5 in the early '70s and QA activities that are now being 6 conducted in the early '80s or as late as half a year ago.
7 Could you somewhat clarify that for me? I mean 8 what was the QA that was applied when the work was 9 originally done?
10 MR. LUNDIN: It was done to Wismer-Becker's 11 program at that time and the inspections and tests that
() 12 were required to be performed, we verified had been 13 performed. We could not find evidence that this one 14 inspection that was required had been performed.
15 MR. SCHIERLING: By W i sme r -B e c'< e r .
16 MR. LUNDIN: By Wismer-Becker. It was within 17 their responsibility to perform that and we could not find 1d the evidence that it had been performed.
19 We did look at all the inspection requirements.
20 We verified both by actual inspection on our own of what 21 was available to be seen, a visual inspection of all four 22 loops. as well as verification by the documents required 1
I l 23 by their program that they had performed all the required 24 inspections.
25 The goal was to assure that the implementation l
l TAYLDE ASSOCIATES 1625 I Street, N.W. - Suite 1904
.. mm
20 1 of their pr9 gram in that what they required to be done to 2 assure that the piping was satisfactory was in fact done.
3 This was an exception that we found.
4 MR. SPRAUL: So there were radiographs available 5 of code welds?
6 MR. LUNDIN: That is correct.
7 MR. SPRAUL: And indications that visual 8 examinations had been completed acceptably and everything I
9 was okay with this one exception of some lug removal areas 10 did not have a penetrant examination recordi is that 11 right?
j 12 MR. LUNDIN: That'is correct.
)
13 MR. SESTAK: Single, not plural. One indication 14 was found and there was an inspection performed on all 15 four loops.
16 MR. SPRAUL: Now you are talking the '83 time 17 frame. I am looking back at the '73 time frame records.
18 Everything was there except for this one non-destructive 19 examination of lug removal areas?
20 MR. FRIEND: The record of a non-destructive 21 examination.
22 MR. SPRAUL: Was not available from the '73 time .
23 frame..
24 MR. FRIEND: That is correct.
() 25 MR. SPRAUL: The work was done in '83 with one TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006
21 0(~N 1 reject area by Pullman which was subsequently found to be 2 acceptable to the code.
3 MR. NORTON: Yes.
4 MR. FRIEND: That is correct.
5 MR. LUNDIN: In the total review of 6 Wismer-Becker there were in other file numbers cases where 7 we did not have documentation for specific inspections.
8 However, we found there was evidence the~ inspection had 9 been performed and documentation that it was successful by 10 other 11 documents. This particular case is the only case where we 12 found that we could not find any evidence of that 13 inspection.
14 MR. CHANDLER: Now your close-out on that then 15 is based on the corrective action that was done rather 16 than on some revelation concerning the initial finding 17 that was made 18 MR. LUNDIN: That is correct.
19 MR. CHANDLER: It is an otherwise valid finding 20 then that there was a deficiency of some size in 21 documentation with respect to that single item.
22 MR. LUNDIN: That is correct.
23 MR. DICK: Craig, I wonder if it wouldn't be 24 helpful to put your overall effort in some sort of f) 25 perspective. Obviously it went beyond a simple audit, and v
TAYLDE ASSOCIATES 1625 I Street, N.W. - Suite 1804 Washington, D.C. 20006 _ _ _ _ _ _ _
1 22 l 1 I wonder if it wouldn't help the frame of reference here 2 of the meeting if you or Frank would discuss the number of 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> you spent and the number of things you looked at and 4 that sort of t h . 9, 5 MR. LUNDIN: The overall effort, as you 6 mentioned, was not an audit. It was an evaluation, and as 7 such was performed in a manner such as to look at as much B as was necessary by our people in the field to determine 9 that an area or a process or a piece of the program or i
10 some hardware was acceptable.
11 To that end, for example, all the loop piping 12 was visually examined. We performed visual inspection on
(}
13 all the available that wasn't in concretc or couldn't be 14 seen of piping and structural work within the two I
15 contractors that we could get to. We recreated as much of 16 the actual inspection as possibly could be done.
l 17 In looking at the program and the 18 documentation to assure that the appropriate inspections 19 and so forth were performed, we looked at a significant 20 volume of the records and when problems were seen or 21 things we didn't understand, those threads were followed 22 throughout the documentation to assure that it was not a 23 common problem.
24 We have some numbers, actual numbers of items 25 inspected and the physical installation of 2,298 items and
(
TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1804 Washington., D.C. 29806___ . _ _ . _ _ _ _ _ _ _ _
I l
23
>O 1 we probably have numbers of pieces of paper, but I think 2 it is more appropriate to say that we just virtually 3 looked at everything that we could.
4 We had several people there in the neighborhood 5 of eight weeks I believe on site full time doing a full 6 evaluation.
7 MR. SCHIERLING: How many people did you say?
8 MR. LUNDIN: How many people did we have on it?
9 MR. BARANOW: We had 10 people I believe.
10 MR. LUNDIN: Ten people full time reviewing both 11 the documentation required by the program and by the codes I 12 as well as the actual hardwa e within the scope of these
[~')
v 13 two contractors.
14 MR. NORTON: How many things, and I use that 15 term " things," did you look at that could have resulted in 16 a finding or an observation, and I know you can't give us 17 a precise number, but are we talking about a couple of 18 dozen, are we talking about a hundred, or what are we i
19 talking about?
20 MR. LUNDIN: Tens of thousands I think as an i
21 order of magnitude, f i
22 MR. NORTON: So ycu looked at tens of thousands 23 and had 29?
24 MR. SESTAK: Nine physical findings for
() 25 Wismer-Becker in the piping area.
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l i
24 1 MR. COOPER: Nine physical potential findings 2 which were resolved into one finding.
3 MR. NORTON: But you looked at potentially tens 4 of thousands. In other words, if nothing had been done 5 right you could have had tens of thousands of potential 6 findings?
7 MR. LUNDIN: Correct. The degree of 8 magnification was as great as we could make it on the 9 physical verification at this point in time. We did not 10 reperform anything and there are some things that just 11 can't be seen.
/~N 12 MR. SCHIERLING: Bill, let me ask you another ;
13 question in a broader sense. Do you intend at this meeting 14 to go through each one of the EOIs?
15 MR. COOPER: We could, but we did not intend to 16 do it. What we intended to do, by the way, in the 17 revisions if these ITRs was to present roughly a one-page 18 summary of each of the EOI files giving more detail as to 19 what the nature of the response was from PG&E, what the 20 evaluation result was based upon, that is was it simply 21 based upon the resolution sheets we got from PG&E or was 22 there additional field work done and so forth, and a l 23 little more about what the nature of the resolution was.
24 The present ITR has a fault which we hadn't 25 recognized would be considered such. We essentially say 1
(
l f TAYLOE ASSOCIATES l 1625 I Street, N.W. - Suite 1904 l _ - - -
Washington, D.C. 20006
25 1 that each of these observations was looked at, evaluated 2 by the Findings Review Committee and found not to be of 3 safety significance, not to significantly impact the 4 plant. That is the reason for the term " observation."
5 What does not come out clearly in those present 6 drafts, and this is what we are trying to do in response 7 to your first concern was to give a little more detail as 8 to why that is so.
9 If you have got a favorite, I suspect the 10 fellows could go into that for you today, or they could 11 give you an illustration about one or two of the 12 observations that were more significant to indicate that 13 the trail was not dissimilar to what was done on 90-26, 14 recognizing of course that they were of much less 15 significance. Go not every one of these steps was 16 followed.
17 MR. SCHIERLING: Let me check with staff for 18 just a moment.
19 (Brief pause by NRC staff confer.)
20 MR. SCHIERLING: Let me ask you, when do you 21 think you will come out with the revised ITRs?
22 MR. COOPER: We were expecting to next week if 23 there is not some new development from this meeting. I had 24 said earlier that perhaps we had not understood your 25 second point fully and our response to that was perhaps
(}
TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006
26 O
1 too little as we had intended it and, depending upon how 2 the conversations go today, it may be decided that it is 3 advisable for us to expand on why we came to the 4 conclusion that there is no real problem here and why we 5 came to the conclusion that there is not a generic issue 6 to be faced based on the work that we have performed.
7 Now to the extent that we need to do that in 8 the ITR, it may slow us up a few days, but we need to have 9 more discussion in that area to see if it is necessary to 10 do that.
11 MR. SCHIERLING: Okay. Let me propose this then, 12 that maybe we take a few examples of the specific EOIs and
)
13 I think it will suffice if within a week or so we will get l
14 a revised ITR and maybe even an advance copy of it in a I
15 draft form or whatever it might be.
16 I think indeed we should concentrate more on 17 the second aspect which is the general conclusion that the 18 QA program that was used and implemented is acceptable.
19 I would like you to maybe address on what basis 20 you determined, and hopefully you can do that for all five 21 EDIs together, the five EOIs that you determined to be 22 invalid.
23 MR. COOPER: Well, let me respond to that one 24 directly and first because we can get those out of the way l () 25 pretty fast.
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27 v
1 That was a procedural matter and there is 2 correspondenco on this that has been made available to all 3 parties. There was a misunderstanding at the site on the 4 part of the review team as to the extent to which these 5 concerns could be expressed to the PG&E people and 6 resolved on site. As a result of that misunderstanding, 7 there were five items that the site team resolved 8 themselves and had no intention of even issuing a 9 potential finding on.
10 I felt that we had to play this thing extra 11 carefully as far as the independence aspects were
(\ 12 concerned and I instructed FIank Sestak to issue those as D
13 potential findings to make sure that everybody knew what 14 the potential concern have been.
15 So those five were issued in that manner. The 16 Findings Review Committee did then consider those and 17 agree with the site team that they were truly invalid.
18 I believe I am correct and, if I am not, one of you guys 19 correct me, but I believe that all five of those that were 20 determined to be invalid were determined on that basis.
21 So that all 24 of the potential findings 22 submitted by the field team to the Findings Review 23 Committee were considered to be valid and were evaluated 24 as to their potential impact on the adequacy of the plant.
() 25 MR. SCHIERLING: Could you go through just one TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006
I 4
_s 28 1 of the five then and express what the concern was and get 2 down to the nitty-gritty of what the invalidity is.
3 (Brief pause - discussions off the record.)
4 MR. SCHIERLING: Shall we take a quick 5 five-minute break and everybody can get a cup of Coffee.
6 (Whereupon, a short recess was taken.)
7 MR. SCHIERLING: Are we ready to start again?
, 8 Let's get back on the record a few general 9 statements before we return to the subject itself.
10 I really would appreciate it if you could move 11 along on a very rapid pace because I personally have a 12 flight at 10 after 1 and I had better make that flight 13 because otherwise you are going to have another Project j 14 Manager.
15 (Laughter.)
16 MR. SCHIERLING: You all are welcome for my 17 funeral, too.
18 (Laughter.)
19 MR. SCHIERLING: I also would like to recognize 20 Mr. Hubbard being here and we will ask you, Dick, at the 21 end of the meeting or maybe during the meeting to provide 22 us with any comments or statements that you feel are 23 appropriate to the subject today.
24 Back to the detailed discussion. With respect
() 25 to the forthcoming revision for both ITRs, can we expect TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washi _ngton, D.C. 20006
29 p
G 1 to have at least the amount of detail that you provided us 2 with, for example, on 9026 in that revision, and hopefully 3 maybe even more as you deem necessary, but this is about 4 the minimum information that we would like to see in the 5 revitian.
6 MR. COOPER: It is equivalent I believe.
7 MR. SCHIERLING: That would be fine.
8 We want to make sure that we address the second 9 question in our letter to you and let me quite specific 10 there. I am looking at, for example, ITR 30 where, and we 11 can take either one of those two, you frequently make 12 statements that something was found wrong with respect to 13 a specific PG&E specification. Is it specification or what 14 is the proper word?
15 MR.' COOPER: That is as good as any.
16 MR. SCHIERLING: We want to know what we are 17 talking about for the record.
16 MR. COOPER: We will interpret it generically.
19 MR. SCHIERLING: Many of the EOIs have that 20 statement in there and yet there is the overall general 21 conclusion that well, we look at all this, but the program 22 is acceptable.
1 l 23 As we discussed over the phone and as you know, i 24 Bill, this is our concern, how can we come up with that 25 general conclusion based on granted maybe only less than
(
! TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006
30 1 30 EOIs issued on an enormous amount of information that 2 you looked at, and I hope you will address that later on.
3 hR. COOPER: I would suggest that the best thing 4 to do is to get the questions out of the way on this first 5 item and then turn to the second, because it is really on 6 the basis of having done everything we did with respect to 7 these, well, the field investigations resulting in 8 potential findings and resolutions of those, that we felt 9 we were in a position to make a judgment as to the overall 10 significance 11 Just to get ahead though for just a moment, 12 when I reread and others rer'ead that last paragraph that 13 you are referring to in our ITRs where it said it met the 14 specification, in a few regards it clearly did not to the 15 letter of the law meet the specification in the sense of 16 meeting a regulation perhaps, but it clearly ended up with 1
17 an equivalent end product for the service requirement.
18 It is that kind of rewording that we had 19 attempted to put in these revisions and which I am 20 concerned now hasn't gone far enough which we can benefit 21 from on the discussion.
22 To the letter of a detailed lawyer reading of 23 the specification and what'was done, it may not have 24 precisely met that detailed work, but it was clearly an
() 25 eqivalent kind of thing in those few instances where it l
l i TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006
31 1 didn't meet the detailed work. I think to get into that 2 area at all we do have to resolve any concerns you have 3 about the way in which we resolved those specific EOIs.
4 The question that was on the floor just before 5 t.2 break was give us an example of one of the five we 6 ruled invalid, which we are now prepared to do and then we 7 suggest we look at some of the observations.
8 MR. SCHIERLING: Very good.
9 MR. COOPER: Craig.
10 MR. LUNDIN: Just after we reconvened, I sat and 11 just flipped to see the first ones that we had. As an j 12 example, a potential finding' report was issued and
(}'
v 13 subsequently cancelled. However, cue to the procedural 14 problem we had that Dr. Cooper mentioned, we issued it, 15 but in this particular case there was a specification 16 requirement that PG&E review and approve the weld 17 procedures used by Wismer-Becker.
18 We found weld procedures that had not been 19 reviewed and approved. There was no evidence of that 20 approval and subsequent checking found out that those were 21 not weld procedures that had been used on that work. So 22 they were part of Wismer-Becker's weld procedure book, but 23 were not used for Diablo Canyon, Unit 1 and there is no 24 reference to them in the records. That was subsequently 25 cancelled.
TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006__
I i
32 1 We have two that were written specifically ---
2 MR. SCHIERLING: In other words, that finding 3 was not applicable.
4 MR. LUNDIN: That is right.
5 MR. COOPER: It is invalid, is the program 6 working.
7 MR. LUNDIN: We have two that were exactly that 8 way. We had one which was a potential finding on the 9 radiographic report did not denote the status of its 10 review. In this particular case in fact it was not that 11 the radiograph did not exist and it was not that it was 12 not well documented. The review had been performed.
l 13 It was a case of, and I don't remember the 14 exact way the form was designed, but it was that he did 15 not check the accept block and subsequently the team 16 assured that in fact the radiograph was in fact 17 acceptable. It was obvious that it had been reviewed, but
( 18 the block for accept had not been checked.
l 19 When it was verified that in fact the 20 radiograph was acceptable, and there was other 21 documentation to show that that individual had accepted 22 that radiograph, the pctential finding report was 23 developed.
24 Once again, it was issued as an open item l
() 25 report because it had been sent to the Findings Review l
l l TAYLOE ASSOCIATES l 1625 I Street, N.W. - Suite 1904 i
Washington, D.C. 20006
33 1 Committee.
2 Let me find another quick one here.That in 3 general is the type.
4 We had a potential finding on a piece of paper 5 that was not in the file on the certification of some 6 penetrant material. Subsequently the document was 7 available and that would not have been a finding if that 8 had been available at that time.
9 That characterizes I think the type of invalid 10 findings that we had.
11 MR. BISHOP: Could we return then to the one I } 12 example you talked about earlier on how the IDVP used that 13 example. It followed up on the particular issue of the 14 pipe lus removal.
15 We are interested, and this is central to our 16 concerns in both our question 1 and 2 in the letter to 17 you, we are interested in knowing the process you used in 18 determining whether this was symptomatic of larger l 19 problems.
l 20 You determined I guess that records were not 21 available and that non-destructive examinations were made 22 of areas where the lugs were removed.
23 Our question would be did you conclude that the 24 conctractor in fact did not have a program to check that
() 25 type of effort? And if he didn't have a program, should he i
TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 M
34 1 have had a program? Does that mean that there may be other 2 ASME pipe out there that wasn't within your limited 3 sample that has had lugs removed off of it that hasn't 4 been examined? Those were the types of questions we were 5 interested in.
6 Tied to that we notice in your program plan, 7 which was submitted to the NRC. that you indicate that the 8 Findings Review Committee will define criteria for 9 determining the degree of impact of the potential findings 10 on plant adequacy.
11 Could you indicate how that criteria was 12 applied in this case to tell'us something about the 13 overall adequacy of the programs?
14 MR. LUNDIN: I would like to go back to the 15 first part of your question.
I 16 As far as determining the symptomatic, No. 9026 17 is a good example. We did not have a limited scope of our 18 check. We looked at all the required inspections that 19 should have been done on that pipe and verified that they i
20 had been done.
21 Wismer-Becker did have a process or a program, 22 if you will, to assure that those things were done. If in 23 fact this LP had never been performed, then they may have l 24 not followed their program or someone had made an error in 25 implementing the program.
TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904
, _ - . Washingtong D.C._28906
35 1
We did assure that'not only did they have a 2 Program utilizing their operation Frocess sheet, and they 3 had a manual which would be of course in accordance with 4 ASME 3, but that the process sheet did not pick up this 5 required inspection. That iU,where it would normally be 6 and that is where it was for other inspections.
7 So as far as the ASME piping is concerned that 8 Wismer-Becker installed, we did ensure that all the 9 inspections had been done and this was in fact an 10 exception that we could not find the documentation that l 11 their program had in the process.
() 12 13 The program existed to make sure that all the requirements of the specifications got through the l
14 processi documented and processed through the loop.
I 15 The Findings Review Committee, as you 16 mentioned, developed the criteria. We made the check list 17 for ourselves, a question and answer type of check list to 18 process the typa of findings. In doing so we wanted to 19 evaluate whether we had a problem that was symptomatic, 20 whether we felt we should be asking the site team to look I
21 at something else to show us something.
22 We looked at whether we were talking about 23 someone making an error or an actual program problem that
, 24 we could expect to see repetitive, like something never l
( 25 being done because the program had a fault in it.
1 TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1004
n v
1 Those are the types of questions we used. We 2 also considered whether the feature or the specification 3 requirement was an implementation of an essential design 4 feature of the plant or was for the overall requirement 5 added to the specification to complete the overall 6 installation, such as we had open items on some of the 7 surface finish requirements in concrete which is in the 8 specification.
9 It was a specification requirement and the 10 minor deviations we did see our inspector wrote up in that 11 he took the letter of the law for what the requirements of 12 the spec were for the surface finish of the concrete. But 13 in fact, in an overall review it was strictly within the 14 confines of a cosmetic surface finish of the concrete.
15 So we did make those determinations, the 16 Findings Review Committee, and considered all those 17 aspects in our review utilizing a check list for 18 ourselves.
19 MR. BISHOP: Could you clarify for me on the 20 example we were talking about, the piping issue and the 21 lug removal, did you in fact determine that that 22 contractor did have a program or had a program that thould 23 have checked areas where lugs were removed?
24 MR. LUNDIN: His program should have picked 1t 25 up.
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MR. BIS OP: So you would say in this case the 4
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\ 'S,2 s\'? fact,t3at you found an error was what might be called an 6
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- 3 iisola.ted case as ooposed to a deficiency in the program?
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, 4' s. MR. .LUNDIN:
It was an isolated case. In fact, m . . .
5 al,i other features that that program was supposed to pick c
6 up tt picked s,up~and we verified that.
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W 7 MR. CHANDLER: So if you looked at the next lug 8 down, you ha'd documentation of LP testing?
, 9 MR. LUNDIN: No, we are not talking a lug. We 10 are talking a feature. That is some of the lug removal 11 areas we cd Idn't find.
12 HR. BISHOP: That'is what I am getting back to.
.(
13 , MR. LUNDIN: These pieces of pipe, and I believe
.s
' ' 14 they are cast pipe, are delivered with lifting lugs.
5 15 MR. RICHARDSON: Erection.
16 ,
MR. LUNDIN: Erection lugs which may or may not 17 be removed. They do not have to be removed. However, in I
l 19 the normal construction process with restraintsi supports, 19 hangers, if you will, and insulation, it becomes more 20 expedient to the construction forces to remove them. Now
- 1 that is allowed.
I 22 If the lug is completely removed, the code 23 requires it to be LP inspected. If it 1s left on in some 24 part, that is not required because the original weld was
( )' 25 controlled at the manufacturer a r. required, which we did i
i i TAYLOE ASSOCIATES l w 1625,I Street, N.W. - Suite 1904 i _ < _
J t,
- g 38 1 verify.
'2' MR. BISHOP: I still have the question, as Larry 3 would say. You concluded then that the contractor did not 4 have a program to check the surface of where lugs were 5 removed?
6 MR. LUNDIN: If I may clarify. I think we are 7 hung up on what the term " program" is. There was a progrkm 8 to assure that the specification requirements were 9 implemented on process sheets and subsequently through the 10 whole chain.
11 MR. BISHOP: That is very general. I am getting 12 down to the narrow specifics 7
(
13 MR. LUNDIN: Okay. We could not find evidence 14 that the program did implement this specification 15 requirement. It wasn't on that process sheet and therefore 16 we can't find evidence that it was performed.
17 MR. BISHOP: Okay. Then what does that tell us 18 about other piping that may have had lugs attached to it?
19 MR. FRIEND: I thinki Tom, I would like to 20 clarify at this point. It is my understanding that the 21 only piping on the project that had lugs was the primary 22 coolant loop. That is a matter of interest.
l 23 MR. BISHOP: Okay. Then could it be stated that l 24 in fact the entire population subject to that problem has
() 25 been addressed?
TAYLDE ASSOCIATES I 1625 I Street, N.W. - Suite 1904 Washingtono D.C. 29006
i 39 1 MR. LUNDIN: Yes. I thought I had said that.
2 MR. BISHOP: I didn't gather that.
3 MR. CHANDLER: It is not an isolated incidence 4 in the sense of one specific lug removal which had not 5 been LP testad. It is just that LP testing had not been 6 done across the board in lug removal treas.
7 MR. LUNDIN: We could not find evidence that 8 that had been done.
9 MR. BISHOP: That is the type of information we 10 were looking for to get an understanding of whether you 11 looked at the root causes.
12 MR. COOPER: I would think it is important to l()
13 note, although there was no documented evidence that this 14 examination had been performed, that when the examination 15 was subsequently performed that everything successfully l 16 met the requirements.
i 17 Now obviously that can be one of two things. It 18 can be dumb luck or it can be the fact that it had been 19 done correctly in the first place and that the documents 20 are missing.
21 MR. FRIEND: I think it is also of interest that 22 the senior members of the construction group on the site l
i l 23 believed to the best of their recollection that the tests 1
24 were performed. We cannot find the documentation, but it 1
l
() 25 is their memory that these tests were correctly performed.
TAYLOE ASSOCIATES l
1625 I Street, N.W. - Suite 1904 6
40 1 Is that correct?
2 MR. NORTON: Yes.
3 MR. LUNDIN: By the way, we did find in one of 4 the other findings that there was occasion where a test 5 was left off a process sheet but in fact did get 6 performed and we had the record. I think that is in one of 7 the findings as well. That is why it was written up that 8 we just didn't have the record that it was performed.
9 MR. BISHOP: I cut you off when you were about 10 to describe the criteria the Findings Review Committee was 11 using.
12 MR. LUNDIN: Ve11I I think I mentioned most of 13 them earlier, but the things we wanted to evaluate was, 14 first, is the problem sufficiently defined to evaluate it, 15 and that would be an internal process where do we have 16 enough information to make some sort of evaluation to pass 17 on to the Program Manager. That would be where we would 18 ask the site team to do something else or get something 19 else for us or submit more information.
20 We look at the impact on the adequacy of the 21 plant in that can we determine whether it is a hardware or 22 a plant adequacy problem or do we have an error in the
[ 23 implementation of a program. Someone doesn't sign a 24 document, for instance, or there is a piece of paper l
() 25 missing from a file that we have every evidence was there l I TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006
41 1 before. It is not necessarily hardware related. Does it 2 appecr to be an isolated case? That is the first thing. Do 3 we need more information to judge that?
4 Do we have a potential judgment error or a t.
5 individual failure to follow procedures? For instance, an 6 individual judgment error would be a case where the 7 original inspector accepted something and our inspector 8 felt it was rejectable. It is very possible that that 9 person made a judgmental error.
10 Does it appear to be the symptom of a problem?
11 Is there evidence of a system breakdown? Did this come 12 because the system broke down and this fell out the 13 bottom? Were the procedures inadequate? Does it 14 demonstrate a lack of personnel awareness? Does it deviate 15 from a code or a standard? Those are the type of questions 16 we asked and discussed. What may reasonably be considered 17 the effect on the plant if left undetected was one of the 18 things we discussed about each one. Is there a potent 1a1 19 for and product deviations or deficiencies? Is there a 20 potential to affect operability or maintainability? Was 21 there a subsequent check test or inspection to confirm the 22 adequacy of the item?
l 23 When we consider that some things are subjected 24 to multiple tests, one of the considerations we looked at 1
() 25 was well, was it checked later on for some other reason i
i l
l TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904
_ - _ _ - 6
42 1 and therefore we don't need to look at the adequacy of 2 that.
3 Then are the possible adverse effects of the 4 potential finding likely to affect the operability or 5 safety of the plant?
6 So these are the words we used to jog our 7 thought process as we discussed each and every item. We 8 used this as a check list to assure we had discussed each 9 question and that is the type of criteria we used.
10 MR. BISHOP: Okay. Thank you.
11 MR. CHANDLER: While we are still on the l
12 criteria for a moment, you mentioned earlier that you did 13 not specifically use Appendix B as a check list. A lot of 14 the words you say smack of Appendix B and you indicated 15 that there is a relationship between what you did look at 16 and Appendix B.
17 Was a conscious decision made not to use 18 Appendix B or why was Appendix B not used as applicable at 19 any given point in time?
20 MR. LUNDIN: I think you are probably get a 21 different opinion frem each of us on that in that I think 22 each person had their own ideas.
23 Appendix B was considered and really utilized 24 in that our people in writing the check list used the
( 25 attributes that we would use to assure Appendix B.
)
i l
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43 OA g Because it was after the fact, significantly 2 after the fact in that the amount of people and the 3 processes were not in place and operating for us to look 4 at, we felt we had to assure that the elements of any 5 quality assurance program, which happened to be delineated 6 in Appendix B, were in effect to assure that the plant was 7 built right and in fact it was implemented.
i 8 We felt if took an approach like that we would 9 assure that in our evaluation we would be able to make a 10 determination as to whether there were controls in place 11 and they were effective. That was our main goal.
12 By assuring t he elemen t s of a QA program were
(}
13 there that would preclude any question of whether 10 CFR 14 50 applied. I know I have seen some documentation which I 15 believe because of the early license of this plant that 16 there was some consideration as to whether 10 CFR 50 17 applied to Unit 1, and I know that PG&E committed to apply 18 their program as much as possible to that.
19 So it was considered that a quality assurance 20 program, and this is in my participation, the elements of 21 that program as they applied to these two vendors, would 22 be considered.
23 Obviously if we had applied Appendix B from the 24 start, some criteria just would be not applicable to these 25 things.
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44 1 MR. CHANDLER: You are talking about Appendix B 2 as it existed in various points in time. There is no real 3 change. I understand.
4 MR. LUNDIN: I do not believe that that was 5 considered.
6 MR. CHANDLER: Are there different opinions of 7 it?
8 MR. LUNDIN: I don't know. Are there?
9 MR. SESTAK: No, I don't have any vast 10 difference of opinion from Craig. We tried to and we 11 recognized that the so-called PG&E agreed to utilize these .
l T 12 accepted components of 10 CFR 50 en Unit 2 which goes back l
13 into this as much as possible on Unit 1 that is in the l
14 FSAR.
15 MR. BISHOP: Along that same line of thought 16 locking at the program again that you submitted to the i
17 NRC, one of the overall objectives is stated that you will 18 deterine whether the construction of Diablo Canyon was 19 performed in accordance with the quality requirements 20 appropriate at the time and meets applicable regulatory 21 standards.
22 In another area, paragraph 3.2.1, it indicates 23 that you will evaluate the quality programs to determine 24 if controls were consistent with applicable NRC
[^N 25 requirements.
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G' 1 I presume you did this in the development of 2 your check list, is that correct?
3 MR. LUNDIN: Correct, the implementation being 4 the implementation of the specifications and the program 5 requirements and all the documents that we used in 6 developing our check list.
7 MR. BISHOP: In the check list subtask it 8 indicates that you will evaluate each contractor's quality 9 program and procedures. Could you discuss the extent to 10 which you looked at procedures?
11 MR. LUNDIN: Well, I didn't do the evaluation.
12 Maybe somebody on the site team, maybe Fred or Stan could 13 address how far we actually looked at the actual 14 procedures.
15 MR. BEARHAM: I am Fred Bearham. I was on the 16 site team. We looked in great depth at the procedures and 17 we deterined the adequacy as we went along. Most all of 18 the people on the team were experienced people. So they 19 were used to looking for the adequacy of programs.
l l 20 MR. SPRAUL: Was there a manual back at that l
21 time that met code requirements that they developed the
(
22 procedures from?
23 MR. BEARHAM: Yes, there were manuals there both 24 for Wismer and Atkinson and there were programs developed
() 25 from manuals like weld procedures and such like. There TAYLGE ASSOCIATES l 1625 I Street, N.W. - Suite 1904 l N % & NTFM
46 (g
1 were programs for the qualification of personnel, et 2 cetera.
3 MR. COOPER: The Wismer-Becker report, for 4 example, states that a total of 3,528 documents was 5 reviewed.
6 MR. DICK: I think, and Craig, you may wish to 7 comment on this, but I th.nk it was clear that there was 8 an approved quality program that Wismer-Becker was 9 following.
10 MR. LUNDIN: That is correct.
11 MR. BISHOP: What we expected the IDVP to do, l e 12 and I refer to your plan, was to tell us whether that 13 quality program was effective in meeting regulatory 14 requirements at the time.
15 MR. COOPER: I think that the key to our process 16 in conducting this work was to assemble a team of I 17 experienced people both in the field team and in the l
18 Findings Review Committee that were familiar with 19 construction and the application of construction QA at I 20 that time and go out and see if the job was done right.
21 Clearly that experience reflects the growth of 22 the more formal QA procedures during that time period, but 23 we did not want to get into a situation where we are 24 arguing, for example the pros and cons of the FSAR 25 statement that says for Unit 1 the PG&E program would be TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006 _ __
1 used to the extent possible.
2 We didn't want to get into this what is the 3 extent possible. We wanted to get into the question of 4 whether there was a valid QA program which was implemented 5 and led to a construction which was acceptable.
6 I think that our emphasis has been on do we 7 have the right and product more than on is every "i" 8 dotted and "t" crossed that might appear in some 9 interpretation of the various documents.
10 It is true that we don't have a formal 11 comparison in our reports with each of the applicable 18 12 elements because we thought It was more important to find 13 out if things were done in a manner which was good 14 practice at that time in these areas.
15 The emphasis was not on a paper comparison of 16 programs with other documents. We knew that they were 17 working through approved procedures and so forth and we 18 wanted to see how did it work and how well was it done.
19 MR. NORTON: I don't mean to take the NRC to 20 task, but I am a little bit puzzled by Mr. Bishop's 21 questions, particularly his last one. The letter of 22 October 5th, '82 from Teledyne addresed to Maneatis, 23 Denton and Engleken, page 4, 3.2.2 subtask, spells out 24 basically what Mr. Cooper just said is what they were 25 going to do, and that letter is dated October 5th of '82 TAYLNE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006
48 O
V 1
as to what they were going to do in that respect.
2 As I read page 6-1 of ITR 38 Revision 1, they 3 tell you what they did. If you look at the wording of what 4 they said they were going to do in October and what ha 5 just said, all three seem very consistent.
6 So I am a little puzzled when you say you 7 expected something else.
8 MR. BISHOP: Well, I expected to know how they 9 got there which I didn't see in the ITR.
10 MR. NORTON: Okay. That is a different question 11 than what you just verbalized. All right.
j I 12 MR. BISHOP: I would like to proceed with U exploring that particular aspect, and it ties in with our 13 14 second question in our letter to you.
15 Considering that you explained rather well to 16 me and I have a much better understanding and a better 17 feeling of how you analyzed the individual ITRs, and if 18 your depth of investigation was as thorough for the other 19 ones as it was for this finding in checking the broader 20 1mplications of that, I think our concerns would evaporate l 21 in that area.
22 We have a similar concern in how you took into 23 account all these many relatively small items and drew 24 your conclusions about the overall program adequacy.
() 25 Specifically let's take an example on material l
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s 49 1 control, for example. I believe you had a number of 2 individual items talking about mill certs and things such 3 as that. How did the Findings Review Committee handle 4 these many small items, recognizing that each one 5 individually didn't create a problem, but was 1t 6 symptomatic of perhaps a broader problem within that 7 contract?
8 MR. COOPER: I would suggest that we go through 9 a couple of the observations in more specific detail.
10 MR. LUNDIN: Well, I am not so sure one would 11 help, but we shall. For example, we did have some that 12 were on material control. With one exception, they were 13 determined to be programmatic as far as information that 14 wasn't available to us at the time. When those threads 15 were followed, we found out that in fact somewhere the 16 information existed and the material was proper even l
17 though the piece of paper was missing.
18 We checked the material from the reactor 19 coolant system from the hardware back to the paper. In one 20 case we found that at the receipt inspection the
{
21 identification of two itsms on the same shipment were 22 reversed in the records tracing. So that one number traced 23 back to the other piece of tubing. There were two 24 different thicknesses. The material was properly installed. The right material went in the right place. The O 25 TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904
[ Washi 29906
50 1 right size material went where it belonged.
2 Since this was the only case of all the 3 material that Wismer-Becker installed that did not trace 4 back to the appropriate number, we had no reason to 5 believe that this was a common occurrence except isolated, 6 and we did not tie that item because it was under material 7 control under everything that had something to do with 8 material because they were separate and distinct and the 9 others all happened to go away in that we found that in 10 documentation from Westinghouse and so forth where we went 11 beyond the scope of our review to assure that the material 12 was correct.
13 In the case of going to Southwest Fab and to 14 Westinghouse for documents we assured in fact the material 15 was the correct material, although the Wismer-Becker 16 documentation was unclear to assure that.
17 So any particular one that you want to discuss, 18 we can pull out, but I wanted to talk about material 19 because they may all fit under the same criteria, bet they 20 don't necessarily relate to each other and, as I said, 21 most of them went away as with the types of observations 22 were done.
23 MR. BISHOP: That is useful information. Perhaps 24 if you could just inform us in general terms how you drew
() 25 your overall conclusions considering the findings, the TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1984 m _ _ _ _ _ .
<x 51 1 individual findings y o t' had.
2 MR. COOPER: First, we had only one tinding. I 3 have got to keep saying that because ---
4 MR. BISHOP: Oh, let me correct my phraseology 5 there. I didn't mean to indicate that you had more than 6 one finding. I meant considering the results of your 7 investigation.
8 MR. COOPER: The reason I want to go on on that 9 and starting out in the manner in which I did was not to 10 chastise you for your counting ability, but rather to 11 point out that the 23 so-called observations, that they 12 were termed an observation because the potential finding 13 was considered to be valid.
14 There wasn't a piece of paper in the file that 15 it really should have been in perhaps, but then the 16 additional work that was done confirmed that although that 17 piece of paper might be missing, things are as they were 18 intended to be.
l
! 19 So when you ask the question about how did we 20 reach a broader conclusion about the work, you have got to 21 recognize that the number 29 was really much smaller in 22 entering into that question of judgment on that point, and 23 I don't know the exact number right offhand, but clearly 24 the 29 went down to 24 and clearly the right number is
()
25 some place between 1 and 24 of these were things that TAYLOE ASSOCIATES 1625 I Street, N.W. - Sui'a 1904 Washington, D.C. 20006
52 1 really were of the nature that you might be concerned that 2 they could lead to this kind of a generic situation.
3 It is a judgment call at that point to me on a 4 recommendation from the Findings Review Committee and we 5 are going to have to turn to them for the basis on which 6 they felt this was the proper judgment in some detail.
7 Having said all this though, I do want to make 8 it very clear that we are talking about conclusions based 9 upon the program we conducted. We believe we properly 10 conducted the program that we were asked to conduct.
11 The question, for example, were two 12 subcontractors the right number, that is outside of our 13 scope. We did the program we were asked to conduct and we 14 believe that our conclusions based on the work we did are 15 proper, but we can't argue outside of that scope and we 16 don't intend to in any of this presentation.
17 If we can keep it within then what we could 18 possibly learn from the scope of the work we undertook to 19 do, then I think it would be appropriate to turn to the 20 Findings Review Committee and say, hey, you know, of this 21 number thtt is like someplace between 1 and 24, how many l
22 did you really think were potential indicators of generic l
23 concerns and how did you feel about it?
24 I think this is the only way to answer your 25 question. Tom.
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1 MR. BISHOP: That is right, and what did they 2 consider in exercising their technical judgment to draw 3 this overall conclusion?
4 MR. LUNDIN: We did determine and the 5 inf or mat ion that was presented to us gave evidence to the 6 fact that, No. 1, there were in the case of these two 7 contractors quality assurance programs in effect, No. 2, 8 they were being implemented because the evidence showed in 9 the great majority of everything we looked at that in fact 10 these programs were complied with and, thirdly, the result 11 of the application of these programs resulted in our 12 review of not finding anything in the plant that was not 13 in accordance with the intent of the specifications.
14 Those, I think, are the three key points which 15 could probably be expanded upon, but the program was in 16 place and it was implemented, that is evidenced, and we 17 feel in the magnification that we used in looking at the 18 plant itself that in fact 1t essentially worked.
19 MR. CHANDLER: Let me ask something if you will 20 indulge the simple mind of a lawyer on this for a moment.
21 (Laughter.)
22 MR. CHANDLER: Bill offered earlier to pick your 23 favorite EOI and we could talk about it. If you look at 24 EOI 9001, the fact that you found something, and then it
() 25 continues "This file was reviewed and anilyred with the i
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,V 1 additional information provided by PG&E. The Findings 2 Review Committee recommended and t ie IDVP concluded and it 3 was finally resolved as an Error Class C observation in 4 accordance with tho program plan."
5 The fact that you found something, what does 6 that say? Let me ask you, what does that say about the 7 program that was in place with respect to this item? The 8 fact that you found perhaps a piece of paper elsewhere 9 that supported the adequacy of the end product or that you 10 found documentation elsewhere that perhaps justified that 11 appropriate tests were done, does that say anything about "w
g 12 the lack of documentation or' evidence regarding the i s-) 13 particular thing you were focusing on?
(
14 MR. LUNDIN: The program which was implemented l
15 was not, as can be seen from the findings, at all times 16 fully implemented. There were cases where we found that 17 the program was not fully complied with.
18 We don't consider, since we looked at all the 19 features of the program that were supposed to be applied, 20 that with the level of magnification that we applied to 21 the program that findings of that nature would not be in 22 existence under any scrutiny. For instance, in the normal 23 NRC visit to a power plant, there are things found where l 24 the program was not fully complied with, but one has to 25 make the evaluation as to whether it is a generic problem TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006
55 1 or whether that means the program is ineffective or 2 whether there is a lapse in the application.
3 Our view with the magnification, the full 4 magnification of the implementation of the program is that 5 what we found was not significant to show the program was 6 not in effect at all. It was normally in effect.
7 In a very small percentage of cases we did find 8 there were lapses in the implementation of the program, 9 but not as would be expected in the auditing program, i
10 Particularly at the time this plant was built, you have 11 got a level of scrutiny that was not as great as we apply 12 right now.
13 MR. COOPER: Is it clear that that decision or 14 that conclusion as based not on the Findings Review 15 Committee looking at paper, but the Findings Review 16 Committee members actually going out to the site and
{ looking at it to see what was there?
l 17 18 I think that is a very 1mportant thing here 19 that we really hadn't expected to do when we planned the 20 program. That wasn't a necessary step in the program, but 21 it is something they felt they had to do in order to 20 exercise this judgment.
23 MR. SESTAK: I just want to mention that many of 24 the findingins, EOIs, just to highlight some of the 25 magnification that Craig mentioned, were in areas of the TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1804
_ Washington 9,D.C. 2 3 6
% 56 I bottom mounted instrumentation support system which if 2 anyone has ever been down there, it is a latticed type of 3 support where many tubing arrangements are being 4 supported where the system has to be constructed almost in 5 place because of accessibility.
6 What we are talking about is strapping 7 material i carbon steel one inch wide by three-eighths of
. 8 an inch thick, strapped across in a lattice. Some of the 9 welding that was performed on there, that is why you have 10 to see th1s thing to obtain the value of somc of these 11 EOIs.
12 Also, the Wismer-Secker specification of the 13 program, the procedures related to reactor coolant piping, j
14 and sometimes the scope of the specifications or the 15 contractord standard to support systems, and they were 16 trying to implement pressure retaining requirements onto 17 structural requirements and that is what we had to 18 differentiate when we saw these things.
19 MR. CHANDLER: Is that of any significance?
20 MR. SESTAK: No, because this is a normal 21 occurrence. You have a specification or a contract and it 22 expands for one reason or another and sometimes you don't 23 follow up on it immediately.
24 I would like to point out that all of these
() 25 findings that we have -- well, not findings, because there TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1994 Washington, D.C. 20006
9 s 57 1 was only one finding ---
2 (Laughter.)
3 MR. SESTAK: These observations that we have 4 uncovered I think could have been resolved in the same 5 manner then as they have been now. I think that is quite 6 important.
7 MR. CHANDLER: Before Tom goes on s let me stick 8 with that EOI I asked about a moment ago, 9001. When I 9 read that, and perhaps even 9002 and so on, and then I 10 read Conclusions, Section 7, page 7-li "Further, to the 11 extent reviewed the as constructed physical installation 12 conforms to the requirements'o? design drawings and i 13 specifications and the required inspections are performed l
i 14 and appropriately documented," do I perhaps detect in say 15 9001 that we had not a welding problem but a design 16 problem?
17 MR. LUNDIN: No, that was not. The BMI tubing in 18 this lattice work of support structure, the design 19 requirements were put onto drawings. What our potential 20 findings were was that in fact all the drawing i
f 21 requirements have not been met to the letter.
22 What we did in our investitttion was to find 23 that the design requirements had b e e n 6.i e t and that in the l
24 scope of this work, which was a significant amount of l
'\ 25 welding and bolting, there were deviations from the l [O l
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G 1 drawing that were reasonable, but we identified them as 2 not being in accordance specifically with the drawing.
3 For instance, there was some angle iron which 4 was requited to be bolted and in fact it was welded. Ve 5 did go through the process of assuring that it was 6 adequate. To an experienced person it was intuitively 7 acceptable, but the drawing didn't show and welded sp1ces 8 but only bolting. We identified it.
9 To the level of magnification that we saw the 10 welds which was requiured to be & certain length and it 11 was only 80 percent of that length, even though we knew it 12 essentially was a tack weld,'there was a drawing O 13 requirement and it was in fact not met.
14 Our investigation found that only a fraction of 15 that welding was even required to hold it together.
16 Although we may have intuitively thought so looking at the 17 structure, we did verify it in fact.
18 We went through the process of, for instance, 19 on that tarticular EOI on the BMI tubing, we did receive 20 the design criteria and some of the design considerations 21 that were used by PG&E. They referenced their calculations 22 which were available to us and we had all this information 23 and had our engineering division review to concur in the i
24 concept in those considerations that we used before we
% 25 made our determination that those in fact were reasonable TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 liashington, D.C. 20006
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assumptions in the design itself.
2 MR. CHANDLER: It wasn't clear to me when I read 3 this, for example, in 9001 where it talks about short weld 4 length, and then the conclusion that I read earlier that 5 the justification for resolution of this item wasn't that 6 the welding was proper but it was the design that was off.
7 MR. LUNDIN: The design was satisfied.
8 MR. DICK: I wonder if I couldn't help this 9 discussion a little bit because I think I sense what 1s 10 troubling some of your gentlemen. We had a little 11 discussion on closing that gap between not strictly 12 meet 1ng the drawing and accepting the product at the time
)
13 the work was accepted.
14 In the documentation 1 rom getting from one 15 point to the other, for example, I think we did provide 16 you some additional documentation along the line that 17 helps with that.
18 MR. LUNDIN: Well, there ara two important 19 points really come out of that.
I 20 First of all, as far as the volume of 21 information we looked -t, we got down to looking at 22 people's pocket notes when it comes right down to it. We j
l 23 looked at everything that was available. We had some guy 24 track down who had retired a couple of years ago I think
() 25 and get some stuff off of him to just try to put in TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 P'mhin_?lton o_ D. C. _20006
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I 1 perspective what actually happened back then if there 2 wasn't a record. That in fact was done.
3 Secondly, the consideration by the team and the 4 Review Committee goes back to the purpose of the makeup of 5 those organizations in that some experience with what was 6 being done at that period of time ahd to be exercised when 7 we made those determinations.
8 For instance, in 1973 and '74 the sensitivity 9 to as-built drawings of situations like the BMI tubing 10 supports was not as great as it is today. So the 11 possibility that these drawing deviations, although they 12 were not design deviations, may very well, since the 13 decisions made by the people doing the work apparently l
14 were good decisions, might very well have been judgments 15 made by the field engineering people at that time and not 16 all of these were translated. That is a possibility and 17 that is something we had to consider.
18 That process which was the state of the art and 19 was acceptable is what had to be considered in making some 20 of those evalautions.
l 21 MR. BISHOP: EOI 9013 talks about that specific 22 issue about discrepancies between the installation and the
- 23 drawing requirements. Is this the type of thing you are 24 saying where the sensitivity was different?
25 MR. LUNDIN: Right, in that there were O
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(N 1 differences between the installation and the specific 2 drawings requirements, but did not violate the design 3 requirements. They were apparently, and I emphasize 4 apparently, judgments made by the engineering people in 5 constructing because of interferences, and they made minor 6 deviations that did not get documented on the drawing at a 7 later date as as-built, whict. some of those have been done 8 at this point in time.
9 MR. BISHOP: The question that occurred to us 10 when we saw this was was this an indication of lack of 11 procedure compliance on behalf of the crafts and the 12 quality control people?
13 MR. LUNDIN: Yes.
14 MR. BISHOP: You are saying that was the case?
15 MR. LUNDIN: To us it was apparent that all the 16 requirements of the procedures may not have been followed 17 in that case. I cannot identify the specific violations, 18 but that is a possibility that there were procedural 19 failures, as I mentioned earlier, that the program did not 20 work one hundred percent of the time, but in fact it 21 worked acceptably as one would expect a program to 22 work.This was isolated to this one area.
23 MR. BISHOP: How did you get from one point to 24 the other there? If you saying it didn't work, yet it g 25 worked acceptably, I would like to explore, like we did on (d
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1 the one finding, the process you went through to conclude 2 there were no generic implications on this one where you 3 have procedure compliance concerns. How do you again 4 conclude that there is no broader issue here that deserves 5 investigation?
6 MR. LUNDIN: That is two questions. First, I got 7 from one point to the other in that, as I mentioned 8 earlier, any program that is implemented when audited can 9 be found to not be, if somebody failed to follow it at 10 one point in time and that is identified, and they look to 11 see if it is a generic problem and resolve it.
12 Since we looked al all of their procedure 13 compliance as far as it related to whether the paper war.
14 there and the job got done, but since we looked at all of 15 it and felt that this was a failure in an area which would 16 not necessarily mean that the Vismer-Becker people didn't 17 follow procedures. It was, on the contrary, apparent that 18 they normally did.
19 MR. BISHOP: Could you perhaps quantify some 20 things for me. I have looked at the tubing supports myself 21 and agree with you that it looked like a guy would have to 22 hang by his heels or have a very difficult time assembling 23 that. Could you give us a rough approximation in numbers 24 of the other types of supports, the numbers of other 25 supports you looked at and whether they obviously came out i
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1 satisfactory and there were no potential findings on them?
2 MR. LUNDIN: How many supp:rts in the cooling 3 system, would you say?
4 MR. BEARHAM: There were about four or five 5 major supports on each coolant loop and we looked at those ,
6 thoroughly. I don't think we reported any discrepancies in 7 those.
8 In the BMI tubing very quickly I will say there 9 are probably 100 or so supports in there. We went over the 10 whole thing with a fine toothed comb and got three guys 11 down there most of the time just going through the whole 12 thing. We reported what we found and the numbers that came 13 up are in the report, and I would imagine that ---
14 MR. COOPER: 2,298.
15 (Laughter.)
16 MR. BEARHAM: No, there weren't that many major 17 supports.
18 MR. COOPER: Not that many major support un1ts, 19 I know.
20 MR. BEARHAM: They were large. There were about 21 three or four major ones in each loop. In the BMI tubing 22 there were sort of in the hundreds I would say and we 23 looked at each component and each weld on each support, 24 too.
( 2! MR. FRIEND: So that is an important point.
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Although you looked at say four primary coolant loop 1 2 supports, you looked at all the welds on those supports.
3 MR. BEARHAM: Yes.
4 MR. FRIEND: So you looked at tens or. hundreds 5 of feet of welds in that inspection.
6 MR. BEARHAM: Yes, certsinly and hundreds of 7 bolts. I think what you see is significant inasmuch as 'de 8 looked at hundreds, and enough to sort of make you ask 9 questions I guess, but we certainly went through the whole 10 thing and by far the majority war good.
11 MR. BISHOP: I think it would be useful to
~
12 indicate the comparative level of what you looked at to 13 what you found.
14 MR. COOPER: Vell, let me read it. "The SMI 15 tubing records consisted of two packages which contained 16 the documentation of all 350 welds. These records were 17 examined for evidence of correct documentation, of correct q 18 weld identification, assignment of qualified welder, i
correct degree, correct electrical characteristics, visual y 19 20 inspections and the repair data."
21 MR. BISHOP: I was speaking specifically that he 22 indicated there were hundreds of supports and here it
- 23 indicates three supports had these major weld problems.
24 That is quite a difference.
i 25 MR. BEARHAM: Well, I think it will show you how
)
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1 many supports we looked at and, if not, a scrutiny of the 2 drawings would show you very quickly.
3 MR. LUNDIN: Might I clarify. We are talking 4' about numbers of supports in BMI. It depends on whether s 5' you - could welds or count the little straps or just count 6 the' angle irons going across which all these straps go to.
x 7 How many supports are there underneath, I would have to s .. S a 'J k the guy who designed it what he considered to be a 9 support. There could be hundreds or there could be ten.
10 MR. BISHOP: I am trying to compare the number 11 of supports 9, 10 and 11 to what is the total population 12 there we are talking about, Because we say the majority of 13 welds on supports 9, 10 and 11 exhibitec problems.
14 MR. ETZLER: By that counting there were 11 15 total. There were 11 major locations of straps.
16 MR. BISHOP: Okay, that is different than 17 hundreds.
18 MR. BISHOP: I don't want to belabor the point 19 about numbers, but getting back to the issue on programn 20 and procedures, could you quantify for us the numbers of 21 procedures you may have looked at. You indicated that you 22 looked at great depth of procedures. Would it be 23 appropriate to say that for all the hardware you inspected 24 you looked at the corresponding procedure that related to
() 25 the fabrication of that hardware?
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1 MR. BARANOW: Yes.
2 MR. LUNDIN: I believe that is true.
3 MR. BISHOP: You are getting into the realm cf 4 close to 100 percent review in that sense.
5 MR. LUNDIN: Right around there.
6 MR. BEARHAM: It was close to a hundred percent 7 review of what was actually in the scope.
8 MR. SPRAUL: More installation than fabrication 9 though, was it not?
10 MR. BEARHAM: Well, it depends on what you call 11 fabrication. Of course, we didn't get into off-site 12 fabrication.
13 MR. SPRAUL: Field fabrication.
14 MR. BEARHAM: Some fabrication would have been 15 done in the field, yes. Most of it would have been done in 16 the field.
17 MR. LUNDIN: If it was done by Wismer-Becker or 1B Guy F. Atkinson, whether it was fabrication or insulation, 19 we looked at it. If it was fab by someone else, we only 20 assured that Wismer-Becker's program of receiving it and 21 utilizing it was followed.
22 MR. BISHOP: We had the indication I think from 23 our inspection program that in the performance of your 24 review of the two contractors you did find it necessary to l /) 25 some limited degree to get into the work or the products l %-)
f l TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 L Washington, D.C. 20006
i 1
of subcontractors or vendors, and I think you just touched 2 on that subject. Could you tell us the extent of 3 involvement?
4 MR. LUNDIN: An example would be Westinghouse 5 documentation and we did go to Southwest Fab to assure on 6 the lugs. We needed some information as to whether an 7 initial potential finding was written concerning whether 8 the material actually met the specification requirement 9 and we had to go back to Westinghouse to find out that 10 that requirement had been revised during the process of 11 them buying it.
12 That was outside the scope because it was 13 supplied to Wismer-Becker by Westinghouse, but we did go 14 back to assure that that material was acceptable as 15 purchased by Westinghouse and the documentation is in the 16 file from Westinghouse that that process was appropriate.
17 We did in fact go back to Southwest Fab's 18 records to make sure that they had in fact properly 19 documented the welds where these lugs were removed, that I
20 that was appropriately done.
21 We did have someone go back to get documents, 22 for instance, the Magnaflux supply, the copy of the
- 23 original document that was sent to Diablo Canyon in 1973 24 for that can of penetrant, the one piece of paper that 25 wasn't in the file. Over the years an auditor kept it in f'\
G l
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1 his book or something.
2 (Laughter.)
3 MR. LUNDIN: It did exist and Magnaflux still 4 had it and we did go back to make sure it did exist.
5 MR. CHANDLER: What did you do? For example, you 6 mentioned a number of major subs to GFA in ITR 36, Pacific 7 State Steel, et cetera, et cetera. How about those?
8 MR. IVES: Dick Ives, Stone and Webster. If you 9 look at our check list, when we came up with an inspection 10 attribute or evaluation attribute, we then listed where we 11 obtained that attribute, whether it was from a 12 specification or Atkinson's QA program or someone that was O- 13 working for Atkinson, and that is identified on the check 14 list.
i 15 MR. BISHOP: One last question on the breadth of 16 your sample. In your Wismer and Becker ITR you list four 17 systems, reactor coolant system piping, pressurizer surge 18 line piping, BMI tubing and reactor vessel leak detection 19 line. Of these four " systems" what percentage of each of 20 those systems did you examine?
21 MR. BEARHAM: A hundred pecent.
22 MR. LUNDIN: A hundred percent of all of them.
l 23 MR. BISHOP: My question is for PG&E on a l 24 slightly different subject, but there was a recent problem that was reported to us and it was reported that that r~} 25 l
l l
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I 1 Particular problem on the reactor coolant system piping 2 was not one of the samples looked at by the IDVP.
3 MR. FRIEND: Was that reactor coolant piping or 4 component cooling water?
5 MR. TWIDDY: You at a talking about the thin 6 wall?
7 MR. BISHOP: Right.
8 MR. TWIDDY: That would not have been something 9 these gentlemen would have looked at.
10 MR. FRIEND: That is correct, Tom. They are 11 talking about the wall thickness measurement which is 12 something that the Stone and Webster team did not look at.
13 MR. BISHOP: I understood that.
14 MR. TWIDDY: You see, that was a non-required 15 thing that PG&E was doing in order to d6velop a data base 16 for the future.
17 MR. BISHOP: I am familiar with that. I was just 18 wondering about the statement that was made to us that it 19 wasn't something the IDVP looked at.
20 MR. TWIDDY: Right.
21 MR. BISHOP: What you meant was that IDVP had 22 not considered that element, but in fact had looked at 23 that pipe for other things.
24 MR. TWIDDY: Yes, for other things.
() 25 MR. LUNDIN: The only thickness measurement we I
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1 looked at was as relating to the lug removal.
2 MR. BISHOP: All right.
3 MR. CHANDLER: Weld driving also.
4 MR. FRIEND: That particular weld was a shock 5 weld.
6 If I may, I would like to expand a little bit 7 on some of the remarks that Mr. Lundin just made. When 8 PG&E and the project were considering this program, we 9 wanted to obtain exactly the kinds of things that Mr.
10 Lundin outlined.
11 We wanted a firm that understood what a 12 nuclear power plant was about and the important features Oi 13 that went into the construction, and that was one of the 14 considerations of why we selected Stone and Webster, 15 because we felt they had the experience and the judgment 16 and the knowledge to go beyond the written record if there 17 was a question, to go to the supplieri to go to the shop,
(
18 to go to the mill cert and so forth, because we wanted an 19 independent assurance that what our beliefs were that the 20 plant was constructed well, we wanted that independent 21 view from an experienced person, and the kinds of things 22 that Mr. Lundin has outlined gave us that assurance.
23 MR. BISHOP: My only concluding comment was that 24 I would encourage you to out in the ITR some of the topics you discussed today and the judgmental processes you used O 25 l
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1 to draw your overall conclusions and your individual 2 conclusions.
3 MR. COOPER: We clearly can be responsive to 4 giving more detail in each of the EOI files, what did PG&E 5 tell us, what did we think about it and what was the basis 6 for our classification. That is easy.
7 The overall conclusion to document a judgment 8 is a rather difficult step and we felt that the basis of 9 that judgment was perhaps spelled out by the program plan.
10 Perhaps what we need to do is to place in one
, 11 or both of these ITRs, and I suspect both just because the l .
12 reader might pick up one and not the other, but still an 13 additional appendix which tries to summarize, for example, 14 the page in the procedures that were read saying what the, 15 and I forget just the way it was described, sort of the 16 thought process stimulater list that was read here today, 17 to put that in and build some words around that and some 18 detail about the experience and capabilities of the i 19 Findings Review Committee people so as to give the reader ,
20 some feel that that was a group who could properly 21 implement such a list.This sort of thing we can do.
2? My question to you folks at the end is if you 23 have got any other ideas of the sort of thing we could put 24 in there that would do this job better, please let us 25 know.
j
( <
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1 MR. NORTON: Is it inappropriate for us to 2 request that something be in there? I don't know whether 3 it is in there or not and first I would like to ask. Is 4 that appropriate?
5 MR. CHANDLER: We will even ask Mr. Hubbard if 6 he feels there is something inappropriate?
7 (Laughter.)
e MR. NORTON: I am sure what he wants can't be 9 put in there.
10 (Laughter.)
1 11 MR. NORTON: But my request is not so complex.
12 Bill, in the ITRs do you list the individuals 13 that conducted the audit and their backgrounds and 14 experience and the Technical Review Committee by 15 individuals and their backgrounds and experience, because 16 a piece of paper that comes to a conclusion doesn't weigh 17 much. We would hope it would weigh more when you look at 18 the people.
19 (Laughter.)
20 MR. NORTON: Do you understand? I just think 21 that is important for a reader to ---
22 MR. COOPER: My suggestion is the identification 23 of the capabilities of the team that went out actually in 24 the field in addition to the Findings Review Committee.
[ 25 MR. NORTON: I would like to see a little N.-]/
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f 1 bibliography perhaps.
2 MR. COOPER: I think we can do this perhaps in 3 general terms. I am not sure I want to identify them by 4 name and Frank and I will talk about that.
5 MR. NORTON: Fine.
6 MR. SESTAK: We didn't specify individuals. We 7 specified their qualifications.
8 MR. NORTON: Well, this is a public record and 9 you have identified them all by name anyway.
~
Are all 10 members of the Technical Review Committee here today?
11 MR. SESTAK: That is right.
12 MR. NORTON: Well, I would like to ask a couple 13 of questions of that group.
I 14 MR. SESTAK: The Findings Rev i ew Con.mi t t ee is 15 another ---
16 MR. NORTON: Right, the Findings Review l
17 Committee, I would like to ask a couple of questions of 18 that group collectively and, one, you can answer and then 19 if anybody has a different answer, then the other can.
20 In your review, understanding your scope, do 21 you feel that your review indicated a failure to 22 adequately control the activites of construction i
23 contractors by PG&E?
l 24 MR. CHANDLER: Vould yr, repeat that.
25 MR. COOPER: Yes, repeat that.
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1 MR. NORTON: Does your review indicate to you 2 that PG&E failed to adequately control the activities of 3 the construction contractors?
4 MR. RICHARDSON: No.
5 MR. CHANDLER: Let me make a request, if I can.
6 The principal purpose I would say of the meeting today was 7 to have an exchange between the staff and the IOVP, 8 particularly Stone and Webster, with respect to their 9 evaluations as reflected in our letter to them of May 2nd.
10 Principally the participants were those 1
j 11 parties and PG&E was not listed as a participant. I
~s 12 appreciate the points of clarification that have come out 13 during the meeting, but I really don't think at this point 14 it is appropriate. If we are going to have a meeting that 15 is open, then I suppose it is going to be a lot longer 16 meeting and we will have to extend to Mr. Hubbard the same
! 17 opportunity to pursue questions he may have, and certainly 18 we are going to ask for his comments.
19 MR. NORTON: Let me tell you what the problem 20 is, Larry. You have structured an independence here that 21 doesn't allow me to ever ask these questions, and if I 22 can't ask them at these meetings, I can never ask them, 23 and they are certain germane questions.
24 You know, you can have the right, it is your 25 meeting, and you can tell we to shut up and I will, but I TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 29006
75
~}
%d 1 just want to make it clear that the NRC has structured 2 this independence thing and we are sticking with it to the 3 best of all of our abilities, but you know you put us in a 4 very awkward spot when we can't ask a question.
5 MR. CHANDLER: I don't have a problem. Bruce, if 6 the Project wants to have the same kind of a meeting. Let 7 me just turn it around though and say if we are 90'79 to 8 expand it, that is fine, but I think we have recognize 9 that the meeting we had requested was a meeting with the 10 IDVP, Stone and Webster, to discuss our May 2nd letter.
11 MR. NORTON: Don't you think that question very 12 directly relates to your letter?
! 13 MR. CHANDLER: Oh, I have no doubt that there
! 14 are a lot of questions that you may have that may relate 15 to that, and if you want to continue the meeting, if you 16 will, as a PG&E IDVP meeting, I am sure we can continue.
17 I have just one other question of these 18 gentlemen that I would like to ask them and we can 19 continue on.
20 MR. NORTON: Fine.
21 MR. CHANDLER: The only thing I had a question l 22 about was in both ITR 36 and 38 in Section 2.0 the j 23 statement is made that an appropriate sample for 24 evaluation was selected, et cetera.
f"]
Q 25 I know one of the questions that we had had to f
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1 do with when you say appropriate. What does that term mean 2 and how did you come about that determination?
1 3 MR. COOPER: The term I believe, without taking 4 the time to look at the words, the words "an appropriate 5 sample for evaluation shall be selected" is from the 6 program plan, and I believe when this was written it was 7 simply stated in that language to be consistent with the 8 program plan.
9 I believe the answer you received this morning 10 is that they basically for these two contractors did 11 everything that was physically accessible and avcilable to i
12 do.
0 13 MR. CHANDLER: Okay.
14 I guess, Bruce, before sort of turning the 15 meeting around a little biti I think it would be 16 appropriate to ask Mr. Hubbard if he had any comments.
17 MR. HUBBARD: I think most of my comments have 18 been in the various declarations and affidavits.
19 There really are a couple of things that I 20 would have some interest in.
21 One is that my comment would be that the final 22 report ought to include the check lists that were used as
! 23 well as as many of the filled out check lists as possible.
I
! 24 I think the report ought to have something that l
25 addresses the root causes relative to the QA/QC program.
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O 1 By that I mean where you say " things wara not fully 2 implemented."
3 I think in addition to talking about safety 4 significance, one should talk about what that means 5 relative to the QA/QC program.
6 I think time should be stressed a little more.
7 There seems to be a great emphasis on this, that the B quality being achieved was consistent with the time, and 9 we heard mention of the years all the way from '73, 74 up 10 to some work that was done in 1982.
11 So if there is going to be some gradiation of l
l 12 quality based on time, then I think more emphasis should 1
13 be given to time in the reporting.
14 MR. LUNDIN: Excuse me. There was no 15 consideration of differences in quality and time, but only
! 16 to procedural systems and maybe the level of compliance to 17 those specific things that were done. The level of quality 18 was never considered to be different than it would be 19 today, l
l 20 MR. HUBBARD: Well, there seemed to be slidiing 21 scale on criteria for acceptability based on time and it 22 would help me to understand what was the standard for good 23 practice in the various time spans that you were looking 24 at.
25 In terms of counting, if we do get into l
9 TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 29006
70 l '
1 counting, a number of the observations talked about things 2 in plural. So if we are going to get into counting, I 3 would request that we also count the observations in their 4 plurality so we know exactly what they mean where you say 5 many.
6 Andi Larry, we will be requesting the check 7 list, both the ones that were used by the auditees plus 8 the Findings Committee. We would like those check lists 9 and we would like as many of the filled out check lists as 10 possible.
11 We would also like to understand how the 12 documentation is arranged so that one could go to audit 13 it, and I guess I understand from the various meetings 14 that people are ready for us to come and audit that 15 documentation.
16 MR. CHANDLER: Dick, in that connection, of 17 course, as Bruce advised all the parties, the IDVP has l 18 retained counsel. That is the law firm of Lowensteini 19 Newman, Reis and Alexrad, and their counsel is Mr.
20 Alexrad or Kathleen Shea of that firm I guess, and 21 requests of that nature I think appropriately would be 22 directed to them.
23 MR. HUBBARD: Well, that is very important, 24 Larry, for the record because I think there are a couple 25 of places where the statements were made that the records
}
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I are available and are available for audit or looking at.
2 There was an implication at least that I am sensitive to 3 that nobody has asked to look at some of these and we will -
4 ask.
5 MR. NORTON: I will address this to you, Larry.
6 Ve are in a hearing mode now. We are now under a formal 7 discovery hearing mode. We are no longer in the mode we 8 were in prior to April 21st. We are in a different mode 9 now and any document exchanges and stuff like that is done 10 under formal or informal discovery requests, but at least 11 it has got to be handled through the attorneys.
12 MR. HUBBARD: Well, I would like some more 13 explanation. I didn't think we were into the hcaring mode 14 on construction QA, which this is addressing. It seemed to me we are still into the IDVP event. So that is why I 15 16 thought it was appropriate to ask for those documents as 17 we normally would.
18 MR. FRIEND: Well, this a little more complex 19 than that even I believe in that this program is an 20 adjunct program to the IDVP that was commissioned by PG&E 21 to reach further assurance on the quality of construction.
22 I don't know that this part of the program 23 needs to be necessarily treated in the same manner as the 24 IDVP which was mandated by the commission.
25 MR. CHANDLER: I think though that in any event, Cs I TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006
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1 Dick, in a very real sense, it is a matter that is before 2 the Board and is something before the Board for 3 consideration. To that extent I would have to consider it 4 a matter in litigation and the formal procedures would 5 apply.
6 Though certainly if the counsel for the 7 Governor would formally or informally contact counsel for 8 the IDVP to discuss it, I think whatever is appropriate 9 can be worked out.
10 MR. BISHOP: I would like to offer to you, and 11 it is already available to you, the reports of our audits 12 of that activity. We have had inspections on the
\~' 13 construction QA plan and those reports are certainly 14 available to you.
15 MR. CHANDLER: Through me.
16 MR. SCHIERLING: Did you have anything else, 17 Dick?
18 MR. HUBBARD: No, not at this time.
19 MR. SCHIERLING: Okay.
23 MR. NORTON: I have two questions is all.
21 (Laughter.)
22 MR. SCHIERLING: Well, it is my understanding 23 that time is pressing on, No. 1 and, No. 2, I think it 24 might be appropriate to have a very brief recess and maybe 25 we can meet again in ten minutes.
(
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1 I think at that time parties can make 2 statements they wish to make, including PG&E I propose.
3 Isn't that appropriate?
4 MR. CHANDLER: Yes. Bruce can ask his questions.
5 MR. NORTON: I am just going to ask two 6 questions. I am not going to make a statement.
7 MR. SCHIERLING: Do you want to ask them now or 8 after the caucus?
9 MR. NORTON: I would rather ask them now.
10 MR. SCHIERLING: Fine, go ahead.
11 MR. NORTON: I think I had asked the first one,
, 12 but while this was going on I wrote it out so I will ask
!O 13 it again, and I also heard somebody answer it, but this is l
14 to the TRC.
15 Did your review indicate to you that PG&E 16 failed to adequately control activities of construction 17 contractors?
18 MR. RICHARDSON: I answered no.
19 MR. NORTON: All right. Does anybody have a 20 different answer?
21 (No response.)
l 22 MR. NORTON: All right. The Findings Review 23 Committee, and I said Technical Review Committee. That is 24 the Findings Review Committee.
l I 25 The second question, did your review indicate l
l l TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 l Washington, D.C. 20006
82 1 to you a lack of aggressive, corractive and preventative 2 actions by anybody?
3 MR. RICHARDSON: No.
4 MR. SCHIERLING: Well, let me make a few 5 statements.
6 No. 1, I think the information that was 7 provided today by you goes far beyond what you reported 1n 8 both ITRs, and I think if appropriately incorporated it 9 will give far better credit to the work that you did and 10 will address many of our questions.
11 I had written down specific questions and many 12 of those were already addressed.
{/)
u-I think it is appropriate, and I want to 13 14 emphasize that again, to include a statement similar to 15 the one that Craig read before, the philosophy on the 16 questions that you asked yourself, what does all this 17 mean? I think that is very appropriate.
18 I do not know how voluminous the check lists 19 are, and I do not know right offhand if there is a l
20 difference between check lists and attributes that you 21 developed, that you were considering in your evaluation.
22 I think they should be summarized in the 23 revision to the ITRs to give a better indication of the 24 depth that you looked into the various matters.
() 25 Although some of the documentation that was TAYLGE ASSOCIATES 1625 I Street, N.W. - Suite 1804 6
o 83 v
1 generated, information that was generated during your 2 evaluation might not be open for audit in general at this 3 time because of the various elements in the hearing 4 process, I think staff still would like to, and I think we 5 can, -look at the records any time, can't we?
6 MR. CHANDLER: If worse comes to worse, we can 7 always ask for discovery.
8 (Laughter.)
9 MR. NORTON: The staff clearly has the right.
10 MR. SCHIERLING: I think staff would like to 11 look probably at some of the details that were generated,
"'s 12 the check lists and the list of attributes. I think we 13 want to do that.
14 MR. SESTAK: Hans, I just want to point out that 15 when I think Region V conducted an audit on us they did 16 review the ---
I j 17 MR. SCHIERLING: Tom Bishop just informed me 18 that we did that already. Where is most of that 19 information located?
20 MR. SESTAK: In Boston.
21 MR. SCHIERLING: It is in Boston.
22 MR. SESTAK: It is in our office.
23 MR. SCHIERLING: Thank heaven.
24 (Laughter.)
25 MR. NORTON: Do you have in the ITRs the program TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1804 Washington, D.C. 20006
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1 itself, the initial program that I referred to earlier, 2 the October ---
3 MR. COOPER: It is not included in there, no.
4 MR. NORTON: Do you think that might be a good 5 appenuix to the ITRs also which sets forth what the 6 program was?
7 MR. COOPER: That would be one of the easier 8 ones to prepare.
9 MR. NORTON: It certainly would.
10 (Laughter.)
- 11. MR. NORTON: I think it would be useful.
l
() 12 13 MR. FRIEND:
MR. CHANDLER:
Somebody might want to edit it.
I think it would be useful as an 14 appendix because I think it would help put some 15 perspective on the findings when you can relate them 16 better to the things you were looking at and the way you 17 were looking at them.
I 18 MR. SCHIERLING: I have to come back to one of 19 the two questions that Bruce just had. In your effort did 20 you look or did you also evaluate the PG&E review and 21 approval of the QA programs by the two companies, in other 22 words, the audit that was exercised by PG&E on tre two 23 companies?
24 MR. LUNDIN: We had an attribute that they were
() 25 approved.
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HR. BEARHAM: We saw evidence of their approval.
2 That is what we looked for, a lead sheet somewhere that 3 showed evidence of PG&E's approval of the two 4 subcontractors.
5 MR. LUNDIN: Also in the non-conformance process 6 the approval of the disposition of non-conformances which 7 was another process. We verify that there is an attribute 8 on the check list to assure that that was done and that 9 was verified.
10 MR. SCHIERLING: And, on the other hand, you 11 also looked at the QA programs and their approval by 12 subcontractors to Wismer-Becker and GFA?
13 MR. LUNDIN: There sere non to Wismer-Becker.
MR. BEARHAM: None to Wismer, no.
14 15 MR. IVES: To Atkinson, yes.
16 MR. SCHIERLING: Okay, those are all the 17 questions I had.
18 Unless there are other specific questions at 19 this time, we can go and take a 10-minute break, readjourn 20 and if there are any closing statements, let's go and do 21 that and we will make our plane.
l 22 We will meet at five minutes after twelve.
23 (Whereupon, a short recess was taken.)
24 MR. SCHIERLING: Are we ready to go back on the 25 record.
l l TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1904 Washington, D.C. 20006
i 86 1 Let's do this. Howard, do you have any 2 statements?
3 MR. FRIEND: Yes. I would like Mr. Dick to 4 address a couple of items that follow up on this morning's 5 presentation as a matter of clarification, if it is okay 6 with you.
7 MR. SCHIERLING: That is fine.
8 MR. DICK: Yes, I would like to clarify just a 9 couple of items which were covered partly but maybe not 10 completely by Mr. Lundin.
11 I believe this complements what he already 12 said, but it takes into account several elements which may l
13 not have btan apparent to these gentlemen.
14 The first subject is that of the program 15 evolution. The evolution of the contractor's program is 16 not as obscure as may appear. It is a relatively 17 straightforward thing according to our observation.
18 PG&E wrote a very detailed specif1 cation in 19 making the original selection of contractors in which the 20 quality assurance requirements were set forth in some 21 detail.
22 The contractors in turn responded as part of 23 their proposals with a quality assurance program. Now 24 those programs were approved by PG&E and I believe the 25 contractors' programs also included provision for
[J)
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1 87 1
,r
$ 1 subcontractors to in turn have programs.
2 Those programs were during the subsequent work 3 monitored by PG&E in accordante with the PG&G program and 4 I believe also by the NRC inspectors in the course of 5 their inspections. The programs were entirely consistent I 6 believe with the applicable provisions of Appendix B.
7 So I think there is a rather clear and coherent 8 trail here on the evolution of the contractor programs and 9 it can be demonstrated.
10 The other point I would like to make deals with 11 the concept of use as is where the constructed product may 12 not be identical with the drawings with which it is being 13 compared.
i 14 In addition to the reasons set forth by the 4
15 IDVP, there are other reasons that we understand also 16 existed. A very important reason was during the erection 17 of the portions of the steam supply system Westinghouse 18 Electric Corporation had its on rite inspectors present 19 and conducted a fairly comprehensive review of the work 20 that was ongoing.
21 We believe that some of their records tended to 22 support the conclusions of the IDVP, that in those cases 23 where there were some departures from the initial design 24 drawings, thst those were duely considered and accepted at
() 25 the time the work was performed.
3 i TAYLNE ASSOCIATES 1625 I Street, N.W. - Suite 1804 Enh6natono @.C. 28806
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1 So this was a real time sort of a review, and 2 it was'not an after the fact type of acceptance made in 3 1982.
4 Ve have also attempted to provide the IDVP with 5 other information that indicated that there was a 6 considered acceptance of the product as constructed.
7 Those are the two essential points that I 8 would like to make.
9 I might mod 11y my earlier statement in one 10 small respect, and that is with regard to the timing of 11 the acceptance of the contractor program. I believe in 12 mist cases it was accepted at the time the contract was 13 awarded, but there was an evolutionary process here. But 14 in any event the contractor did perform his work under an 15 accepted program.
l 16 MR. SCHIERLING: Thank you.
17 Bill or Frank, would you like to add anything 18 at this time?
19 MR. COOPER: Two quick things. One is I was 20 going to talk a little bit about use as is, as Charlie 21 did, because I think it is very important that many times 22 we are better off to use as is rather than try to make a 23 repair, and clearly in that period the documentation of 24 the acceptance of those sort of things were not of the 25 nature as they are today.
%_./
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89 1 Charlie said it all and I am not going to say 2 any i .s r e about that.
3 The other thing is we will commit to do the 4 best job we can in revising these ITRs, including some of 5 the things that we have talket about here today. Our 6 priority will be placed on getting those ITRs issued by 7 the end of next week with as much as we can in as we 8 Possibly can.
9 We recogn1re the need that several partles in 10 this room have to be responsive to certain things where 11 time is of the essence, and we will do the best job we can 12 to include everything. We may fall short in a couple of 13 areas, but we will give our priority to getting these 14 things out on the street by the end of next week.
15 We may shortchange some or all of you on the 16 number of copies you receive, but clearly the normal 17 distribution pattern will be followed as far as the people 18 to whom it is distributed.
19 MR. SCHIERLING: Is there anything else?
20 (No response.)
21 MR. SCHIERLING: Dick, did you want to add 22 something?
23 MR. HUBBARD: No.
24 MR. SCHIERLING: Then any further questions or
(~T 25 comments the staff has?
b i
l TAYLOE ASSOCIATES 1625 1 Street, N.W. - Suite 1904 Washington, D.C. 20006
90 1 MR. BISHOP: No.
2 MR. CHANDLER: No.
3 MR. SPRAUL: No.
4 MR. SCHIERLING: For the sta1f I want to thank 5 all of you for coming out on a Saturday. We are looking 6 forward to getting the information in the forthcoming 7 revisions.
8 I think the information as discussed today does 9 indeed provide the answers to the letter that we sent to 10 you, Bill, and again as much as you can put in there, we 11 are anxiously waiting for it.
12 If there are any complications that you cannot Oi 13 make the schedule, please let us know.
14 MR. COOPER: We will make the schedule.
15 Completeness is the question.
l 16 MR. SCHIERLING: Okay.
! 17 Well, again, thank you very much for coming out 18 on a Saturday, and we will see you again very soon on 19 another weekend. u (Whereupon, at 12:15 p.m., the meeting 20 21 adjourned.)
1 l
i 23 l
! 24 l
25 v
l l
TAYLOE ASSOCIATES 1625 I Street, N.W. - Suite 1804 Wachineton, D.C. 20006
i CERTIFICATE OF PROCEEDI.':GS 3 This is to certify that the attached proceedings before the 4 NRC COMMISSION 5 In the matter of: Diablo Canyon
, Date of Proceeding: May 21, 1983 7 Place of Proceeding: Boston, Massachusetts a were held as herein appears, and that this is the original
, transcript for the file of the Commission.
10
,, Mary C. Simons Official Reporter - Typed 12 Q 13 O
W L A 7n W
,, Officia6 Reporter - Signature 15 16 17 18 19 20 21
- 22 23 24 '
25 TAYLOE ASSOCIATES REGISTERED PROFESSIONAL REPORTERS NORFOLK, VIRGINIA
HISTORICAL FILE -
EF DRAWING CONTROL PROCEDURES ,
TAB NO. DESCRIPTION 1 Handling of As-Built Drawings and Sketches (Field Memorandum 4/6/70) .
2 Drawing Control Procedure (6-14-72/9-11-72) 3 Drawing Control Procedure (9-30-75, 9-1-76, 10-5-76, 3-1-78, 5-10-78, 7-28-78) 4 Instructions For The Operation of Drawing Control (OEI-1, Rev. O, 1-19-79) 5 Instructions For The Operation of Drawing Control (OEI-1, Rev. 1 2-8-79) e /
- s
~ 6 Additions Or Changes To Instructions For the Operation of Drawing Control (OEI-1, Change 1, 2-8-79) 7 Additions Or Changes To Instructions For the Operation of Drawing Control (OEI-1, Change 2, 6-11-79) 8 Additions Or Changes To Instructions For the Operation of Drawing Control (OEI-1, Change 3, 10-21-80) 9 Drawing Control Operating Instructions (OEI-1, Rev. 4, 1-28-82)
- 10 Drawing Control Operating Instructions (OEI-1, Rev. 5, 6-17-82) 11 Drawing Control Operating Instructions (PI-17, Rev. 1, 9-29-82)
HISTORICAL FILE OF DRAWING CONTROL PROCEDURES PAGE 2
( TAB NO. DESCRIPTION 12 Record of Sketches Changing Original Design Drawings -
Drawing 437800 (with attached s.8,ntches 3a* and Sa signed of incorporated by Engineer / Inspector After Checking
, Against drawing revision.)
13 Record of Sketches Changing Original Design Drawings -
Drawing 438064 (with attached dummy sheet used to control full size drawing as-builts and signed of via attgghed field correction transmittal) i e
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April 6, 1970
! FIELD MEMORANDUM
~
l TO: ALL RESIDENT ENGINEERS
)}
Subject:
Handling of "As Built" Drawings and Sketches ,
j Method for handling "as built" drawings and sketches are as follows:
- 1. Initiating: .
i The changes to drawings or sketches showing "as built" changes to be made to other drawings will be initiated by the Engineer's in charge 'of the individual structures. They will be responsible for marking up the print with the proper color pencil giving all dimensions and sufficient information, as explained in M. H. Chandler's letter dated July 30,1968. (Attacked) The same applies to any "as built" sketches that are made. These drawings and sketches should be shown to the Resident Engineer before returning to the drafting department.
- 2. Drafting:
The sketches and drawings will be returned to the Office Engineer. From this point te draftsman will check out additional prints, if needed, to make the D'I u ) threer-t3) marked up copies that are required. He will also make any sketches or drawings that are required to show an "as built" change in detail. After the drafting has been completed a drawing number will be assigned. Following the drawing number the letter "C" for Civil, "M" for Mechanical and "E" for Electrical will be added. For example: DC-4-102-11-140-12 M I
. 3. Checking:
Now that the sketch or drawing has been completed and a drawing number assigned, it will go back to the Engineer who originated it for final checking. After checking is completed the drawing is returned to the Office Engineer for final distribution. 4.~ Distribution: h b The completed product will go to the print room for reproduction if needed,
- ! or transmitting as follows
- again keeping in mind Mr. Chandler's letter. '
[ A. One copy (the original) to be maintained on file in the print room, in a file marked, "as built" drawings-Unit 1 Diablo Canyon Site. B B. One copy to the respective Design Engineer office in San Francisco through f the Manager's office. The following is an exanyle that would be used to send Auxiliary Building "as built" to Mr. 0. Steinhardt. k M.H. Chandler /J.Wl Woodward 1 it Attn: O. Steinhardt C. Copy to Division. h ln v #l# W. R. Herscy l Project Superintendent* Att e'.mt . 9 1 -
+ cc.an incv. c.m C] {Wff d .
. pGwE -- .
FOR 10TRA-COMPANY USE2
# 8 Division OR DEPARmENT STATION CONSTRUCTION DEPARTIEIT FsLE No.
Rt LETTER OF cusarer Foreman's Manual " ' Construction Drawings - Field Corrections O July 30,1968 TO ALL GENERAL FORDEN AND FOREIEN: O All field corrections will be noted on the respective drawings, with sufficient detail so that personnel not fmilie with the job can understand the nature of the changes. Complete descriptions of added or changed equipment shall be shown on bills of material, conduit, and circuit schedules. n Upon the co=pletion of work, two copies of each drawing shall be neatly corrected using the following color scheme. , Betta or Blue Blue Prints Line Prints Removals . ~ Blue Green Additions , Yellow - Red Each copy of the corrected printsshall contain the following information in an area near the drawing title.
~
Field Corrections GM , Date . Legible Si 8nature of Person who made corrections One copy of the corrected prints'will be transnitted along with one set of the cenetruction prints to the division. The other O' corrected copy will be transmitted to the design engineer via the Manager's Office.
"^" ^
O PJNelson:jl Page 700.11 7/30/68 w
= -__ , , , _
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M Mite ( M H.C. CARRY E. EXPEDITED COPY O AD0l't..il AL COPY OF E ARLIER CH ANGE REQUESTED A. A ANCE V APPROVED FOR CONSTRU" TION a ISSUED FOR DID R PRELIMINARY ggAjj//NG NO,43W N.O.S. NOT ON SITE Co. Number Distribution To Roy Dale Copies of Contractor RG a E. Distnbution "Vof D" Drawings Rev Date Copies Prints Date Rec'd Rec'd Spec- Copies Copies Copies Na Made Trans. File Rock Field Relained Trans. Na Returned Destroyed on fi'm
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#b UNITI GM167027 OUNIT2 GM /69972 DIABLO CANYON SITE
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i1 i RIC"l rf7Lg] oncuJ or ~c5E~E'rIons ~
- v. . '/S /f437719 12KV SWITCHGEAlt gACK Ng, Company Drawing Control Sheet ,_,
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s I PACIFIC GAS AND ELECTRIC CO'iPANY DIABLO CMYON SITE , I DRAEING CONTROL PROCEDURE Approved by f,f l{ iic2+ , ~ f ln.w W. R. I!crsey G i l'rojcet Superinter de:n , l
PACIFIC CAS AND ELECTRIC COMPANY Diablo Canyon Site DRAlfING CONTROL PRCCEDURE - 1.0 SCOPE Le purpose of this procedure is to establish and prescribe the manner in which all drawings are to be received, filed, and distributed, as ec11 as to institute the necessary safeguards to ensure that the latest revisions of all drawings are expeditiously transnitted to the contractor, and to have same availabic to con-pany personnel. The details of performing this procedure will be spelled out herein, along with listing and describing the records that will be maintained by the Office Engineering staff. This procedure will be constantly subjected to review and will be revised accordingly when changes are necessitated. 2.0 , ORIGIN OF DRAlfINGS AND SPECIFICATION ADDENDA AND CI!ANGE ORDERS 2.1 Origin of Drawines Drawings originate from the design engineer in reproducibic form. After a draw-ing is approved for construction by the engineer it is returned to Central Files with a requisition for the necessary quantity of prints and reproducible prints, to be sent to the job site. A copy of the requisition is sent to the Stanager, Station Construction, where copics (Xerox) of the requisition are made and sent l to the job site. The requisitioned prints and reproducibles, upon receipt by
!!anager, Station Construction, are immediately forwarded to the Project Super-intendent at job site where they are checked off on a ecpy of the requisitica to verify that prints ordered are actually received. Copics of the verified
\
requisition are returned to !!anager, Station Construction who in turn forwards > one to the design engineer, thereby informing hin that prints ordered are on l l job site. Enclosurc #1 shows a requisition as prepared by the Engineering v Ucrartment. Prints may bc requisitioned from the field in the following manner. Rev. June 14, IM.
s 2.1 Continued C/ , A requisition will be made out and forwarded to the Manager, Station Construction Department, in care of M.ll. Chandler. He will then draw out the tracing and have the required number of prints reproduced and then forwarded to the field along with a copy of the requisition. Enclosure #2 depicts a requisition originating from the ficid. 2.2 Origin of Specification Addenda and Change Orders AdJenda and Change Orders originate in the Engineering Department. Once an addenda or change order has been written, it is reproduced to the required quan-tity and sent to the Manager, Station Construction Department. One copy is retained for the office file and the remainder is sent to the Projcet' Super-intendent. Additional copics of the addenda or change orders can be made on the Xcrox. 0 - 3.0 APPLICATIO:: . 3.1 D.rawing Control Records , 3.1.1 Company Drawing Control Sheets (Enclosurc 5) These control sheets will be maintained for each company drauing received at the site. On this sheet is indicated the current information concerning dates, quantitics, distribution and filing information, of all revisions pertaining to that drawing. The appropriate rack number or numbers for the drawing will be indicated in the lower right hand corner of that sheet. An asterisk and stamp l stating Approved for Construction along with color highlighting will be used \ to indicate Approved for Construction drawings. 3.1.2 Vendor Draving Control Sheets (Enclosurc 6)
- A sheet will be maintained for cach vendor drawing received at the site in the l same manner as the Cc ;cf Dr. wing Control :Sheats. sycp 7 y ._ fy ,.
,, l. .') v . . . . t. i ~ D .'- .s" . ^** t-l l
\ Rev. June 14, 19,
3.1.3 Vendors Drawing Control Sheet for Contractor Field Drawings , etc.
; Sec Enclosurc 4 This form serves the same function as the conpany drawing con' trol shoct except that it is specifically designed for lift type vendor drawings. The forn pro-vides for following the individual lift drawings through their approval stage as well as distribution.
3.1.4 Vendor I olodex Card or Control Sheet Files for Drawings without Record Nunbers (Sec Enclosure 3) . A card or control sheet will also be maintained for ench vendor dr:iwinc that is not acconpanied by a record number. Each drawine will be recorded by vendor drawing nutbers, specification, and last resor't, by vendor nace. All of these drawings are filed in a misec11ancous file by specification. 3.1.5 Vendors Drawing and Inspection !!anuls Record (Enlosure 7) On this form is maintained all the information portaining to vendors drawing
%J and instruction manuals with cross references to the various identification numbers as indicated. The key feature of this form is that it will be filed by type of equipment rather than numerical sequences. This will provide a system that allows an engineer or inspector to locate drawings and/or manuals by type of equipment without requiring knowledge of either record or drawing number.
3.1.6 Transmittal Forn 61-9699 (Enclosure 8) This is a standard company form that will be utill:cd for transmitting drawings to anyone. It will also serve as the basis of establishing a backup record. 3.1.7 Daily List of New and Revised Drawings (Enclosure 9) Each day the print roon personnel will publish a listing of all company and vendor drawings received that day. This listing will also include sketches,
'n3 messages, and phone conversations that constitute a drawing change.
Tucsc company drawings received with a notation, " Approved for Construction,"
" Issued for Fabrication and Installation," " Approved for Planning and ::aterial Rev. September 11, 197.
I[\ U, 3.1.7 Continued Procurencnt," etc. will be noted with an asterisk on the listing. It is the responsiblity of the Resident Engineer to provide the specification number for these drawings and return the signed forn (Enclosurc 9) to the Office Engineer cach' day. 3.1.0 Cn .loh Prawinq Inspection l'.crort (Enclosure 10) L is report will be completed by conpany enginecrs and inspectors at randon as directed by Resident Engineers. The report, when completed, vill be distributed as shoun on the fern. Audits still be performed as often as 'necessary depending on the nucber of new drawings rcceived on the Project, but as a nininun an audit will be made each ucek. 3.1.9 Peceival of Drawines All incoming drawings, specifications and manuals ar e delivered to the print roon directly before any distribution is made. One copy of all sepias without I
~
i V prints received will be reproduced inmediately and placed on tge inspection table. At the same time the balance of the drawings are being spread out on the layout tabic, sorted, counted, and the date stanp placed on cach one. Drawings received frod vendors and contractors will arrive with several copies of an engineering departnent transmittal attached (Sec Enclosurc #11 for sample) . This transmittal will have the vendor's name, purchase order number, record nunber, sheet number, and description on it. The quantity received will be indicated on the engineer-ing transmittal opposite each entry, and will be initialed. A copy of this engineering transmittal listing dates of drawing receivals will be returned to the San Francisco General Office. All 'information will then be entered on the appropriate forms outlined above as required. 3.2 Distribution and Filinc 3.2.1 Information will be provided regarding the number of copics of conpany
/"
i ()T ' drawings to be provided each contractor. Copics of vender's and contractor's Rev. Septenber 11, 117 i L
1
~N 3.2.1 Continued
(% s
, drawings will be transmitted to contractors on the job site when requested by the Resident Engineer cor.ccrned. A letter of transmittal (Forn 61-9699, Enclo-sure 8) will be made up for all drawings transmitted to concerned contractors at their job site headquarters. An original and two copics of the transmittal are prepared, and third copy retained on file which serves as a bhsis for determining what transmittals have not been returned and signed. The third copy is pulled from the file and destroyed when the signed transuittal is returned.
3.2.2 At the beginning of each week the Active File is checked for outstanding transmittals that are unsigned for more than a weck. Those transmittals will be removed, and a statement as follows: According to our records we have not received a signed copy of these/this transmittal (s), either because of loss or mixup between here and there. Verification of your receival of the material is necessary for our records. Picase check your. files and return the copy /copics signed. Thank you.
) 3.2.3 Nhen drawings are received', the following steps are taken:
A. They are all dato stamped. FQU2. B. Drawings are separated into these categorics: contractor, rach, file and tabic copies. C. All drawings are recorded on the Control Sheets. D. Drawings are checked against the . outstanding drawing requisitions. E. One copy of each drawing will be placed on the racks provided for each categroy. All superseded drauings will be remov$d from filing cabincts and racks and des-troyed, except the reproducible, which will be marked VOID - FOR REFERENCE ONLY and filed separately for possibic future reference. When all superseded drawings
, are removed from files and racks, the remaining new copics can be folded, marked with number and revision on the top right hand corner, and filed.
, 3.2.4 For drawings received from vendors and contractors, a divider with the drawing number will be inserted between each new drawing. All of these drauings Rev. September 11, 1972 l_____,, , _ _ ..i.- --
- t O
\,_ / .
3.2.4 Continued
) will be filed ochind the identifying divider. Void drawings will be processed as with company drawings, except that in some cases a print will be retained for futurc reference if there is no reproducible availabic for that purpose.
3.2.5 One copy of cach drawing received each day will be placed on the provided inspection tabic for. the information of company engineers and inspectors. All new drawings, drawing revisions, sketches, DQ's, and TWX's received each day will be listed on the DAILY LIST OF 13T AND PIVISED DRAWINGS, which will be provided to each Resident Engineer, indicating i. hat drawings have been received portaining to their respectivo areas. 'lhe original of this form will be returned at the end of each day to the Office Engineer, signed by the responsibic resident enginecr, indicating that he has scen the list of new drawings received and passed same on to his engineers and inspectors. After 24 hours, clock time, the draw-ings will be removed from the inspection table and placed in the file. 3.2.6 All drawings taken from the files will be signed for by the individual requesting the drawings. This accounting record will be maintained on the out card filed with the drawings. It is the responsibility of the individual signing for the drawing to return same when requested, or when he no longer has a use for the drawing. All drawings issued as sets, such as bid set drawings, will bc signed out as a set and will be returned complete. Under no circumstances vill individual drawings be takcn out of drawing sets. Even if an individual desires
~
4 to check out a drawing that is a part, of a set, he must check out the entire set and keep then together at all times. , 3.3 Inspection Procedures All the procedures up to this point provide the necessary documentation to ensure iI that only the latest revisions of drawings have been transmitted to the con-tractor and company personnel. The procedure for recalling superceded drawings from company engineers and inspectors is covered in paragraph six. Since the l' Rev. September 11, 19L
N 3.3 Continued [O~ contractor on the job site in most cases will be provided with reproducibics of
')
drawings transmitted to them, it therefore becomes incumbent oh the company inspectors or engincors to verify on a wechly basis that all contractors and subcontractors are using the most current revision of a drawing. -This is accomplished by the various inspectors performing visual inspections of the l prints being utilized on the job, and by comparing these against the Drawing Control Sheets to verify that the drawings are current. At the conclusion of a drawing inspection, the inspector wi11 prepare the ON Tile JOB DRAlflNG INSPECTION REPORT (Enclosure 10), and submit it to his Resident Enginec for subsequent distribution to contractor, Quality Assurance, and Office Engineer. 3.4 Superseded Drawing Processing In paragraph 3.2.3 it was stated that superseded drawings will be withdrawn from the. files and (estroyed, with one reproducible marked VOID--FOP. REFERENCE ONLY g and retained for possible future reference. Any drawings that have field notes marked pn them will be taken to the respectivo engineer to see if it warrants an as-built drawing or are the notes worth saving. If the notes are to bc kept, the drawing will be stamped and handled as above. When superseded drawings are h removed from the file, any that are signed for on the out card will be recalled from the individuals by use of Form OE-24, Enclosure #19. If any individual desires to have a copy of a VOID drawing, a print will be made and entered on a ] record that is maintained in the print room. In this manner all copics of VOID-- FOR REFERENCE ONLY drawings in the hands of company personnel will be accounted for at all tines. Superseded drawings in the hands of contractor personnel will be conttolled by the exhaustive inspection procedures outlined in paragraph 3.3. Processing of Sketches and/or Partia n, In order to expedite necessary design changes, or to make small changes in drawings, 8-1/2" x 11" Revisien Sheets will be utill:cd. (Sec Enclosure #12 for sampic). These sheets may be transmitted by company mail oi, where expediency i Rev. .inne 14. 10 T.
O 3.5 Continued N . ~ dictatcs, by telephone telecopier. All sheets are identified by drawing
)
number and sequential numbering procedure, such as 4a, 4b, 4c, etc., which are assigned by the print room personnel and Ehgineering Department. To distinguish Engineering's assigned number from the print room personnel's an asterisk
- will
& w> amt> be added to the right of the number. The sketch number will be made up of a r
bL . Ys 2&dnumeral and small case letter. The nunerni vill represent the next revision o_f that particular drnwing to be used while the letter will represent the sequen-tial order of sketch issuance. At the same time the sketch number is assigned the sketch will be recorded on the Record of Sketches Citanging Original Drawings (GE-2) Enclosure #13. After th_e sketch number has been adde 3 the sketch will ; be taken to the respective Field Engi__neer to examin.e.,. a.n.d he wi.ll let
- -t.h.e
- _ .pr_
_ _ int. roompersonnelknowhowcanycopicstosendtothecontractor.fThenthepiint rcom personnel will attach the sketch to the proper drawing on the rack and issue same to the contractors and field engineers. When a pew revision to a drawing is issued, the print room personnel will detach all sketches, design questions, and San Francisco phone calls and R.'X messages, and return them to the respective field engineer. The engineer will check all of these attachments to see if they have been incorporated on the new revision. If they have, he will stamp the sketch in red ink and fill out the blank per sample shown below. INCORPORATED 01 DVIG.x DWG. 3 0. nru CHG. 7 l DATE 5- ar 19 7a S;GRED &~4. //mevf l
- Rev. June 14,19
"-*'"'a' sHE ET NO. OF SHEET PACIFIC GAS AND ELECTRIC COMP ANY JOB 1 GENERAL COMP UT ATION SHEET ''J
LOC ATION SUBJE 8 = uADE 87 DATE CHECNED BY APPROvFO SY y * *
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i 1 3.5 Continued l ('
') Then he will take the sketches, San Francisco phone calls, design questions,
- and WX messages that have been incorporated on the drawing up'to the print roon i
i so they can add the same stamp to the original sketch in the sketch book which
. will also be signed by the engineer. The original will remain in the sketch
! r bock. The date the sketch was added to the drawb g will bc filled in on the
~
} . j CE-2 form, Enclosurc #13. 1 ! 1 The same procedure will apply to San Francised phone calls and d.csign ques-tions with the only exception being that the original of each will have to bc retrieved from the Specification Correspondence file by the respective engineer j and stamped with the incorpration information. For those sketches that are not 1 incorporated in the new drawing revision, the engineer will use the G-36 (Enclo- . f sure 17), and list all of the design questions, sketches, and San Francisco phone calls and WX messages that were not incor[btated on the previous change I and send it into San Francisco, General Office, ifnen the field engineer has completed filling out the form he will give all of the unincorporated data to the print room personnel who will in turn re-attach all of these to the new change. 3.6 Processing of Drawings Received for Approval [ ; i ' j Drawings submitted for approval from the contractor on the job, that are approved j by the company. Field Office, will be processed just as all other drawings. , I l Coordination of interfacing problems will be facilitied.
- 3.7 Process of Specifications, Iithognphic Sets and Addendums l All specifications received will be accounted for on the Specification and ,
i l Addendum Distribution Record (Enclosuro 14). A specification will be in the i l Specificaton correspondence file or assigned to an individual by initial. Ifnen i addendums are received they are issued to the appropriate holders of the proper l O; l i Rev. June 14, l'.: i _ __ _ .:_ __ _ _ _ _ . . _ _ _ . _ ._. . _.,._u., . _ . _ ._. _ _, .. . .l __. L i_ Z_,
3.7 Continued
) Block on the form. Specification Change Orders will be processed using the form 4
shown in (Enclosure 15). Lithographic sets and addendums thereto will be pro-cessed as above using the form shown in Enclosure #16. 3.8 Aperature Card Listing This listing is provided on a biweekly and monthly basis by City Records Depart-ment. Upon roccipt this listing will be checked by the print room personnel to verify that we have received all the drawings and latest revisions listed. If there are any deviations noted on a call or memo to the City Records Department will be instituted. 3.9 Method for Checking Validity of Vendor Drawings Used for Field Construction hhe'n engineer or inspector receives copics of the vendor drawings from the contractor, he will stamp the COPIES RECEIVED FRO'l CONTRACTOR. 3.D.1 The engineer or inspector will check the contractor's copy against the on file record copy which will have either stamp No. 1, 2, and most likely stamp h'o. 3, all per PRC-11 affixed and checked per sample below. No. 2
~
No. I'- ~ PACIFIC CSS AliD ELEClRIC CO. APPR0?ED TOR CO.'iSTRUCTION APPROYED FOR RECORDED CONSTRUCTION DEPARE a r OF EHGil:EERING . ENGINEERING DEPARli s T
, BY DATE l
I l-No. 3-l PACIFIC GAS Atio ELECTRIC CD. l DE/ARTMENT OF ENGINEERING b Approved is To Substance JJ Subject to I: stations Shown D Not Approved O Furrish Revised Drawings for Approval
,F1 Fur 4 8th rient pressag, pad sege.d .shi.s \ Refer to attached transmittal dated ,
By: Date: Apprenal does not telieve supplier / centracter of resconsibility for correct f abrication and c mpliance eith specification and/or puret.ase e der. RcV. June 14, 1972
- -- ww -- - - - - - -
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3.9.1 Continued I O[ ( If the contractor copy agrees or falls within the permitted for use column PRC-11, he will apply stamp No. 4 PRC-11. Sec below and have stamp signed by
, Resident Engineer or his authori::cd delegate.
NO. 4 APPROVED FOR INSTALLATION BY: DATE: 3.9.2 If all items are installed and the pour is ready to be made, but no final approval drawing has been roccived on site, the resident engineer or one of his delegates may seek teritten approval to apply stanp No. 2 PRC-11. 3.9.3 Uhen the engineering approved copy of the contractor's drawing arrives onsite the approved onsite copy is checked against it. If both drawings con-from to cach other, the engineering approved copy should be stamped with stamp No. 5 belou. ex . l If the two drawings conflict, the Engineering Department should be notified l and cither the engineering approved copy voided or a solution to the conflict presented by the Engineering Department. NO. 5 AGREES WITH APPROVED ONSITE COPY INITIALED DATE 3.10 Informtion Only Drauing i . These drawings, either Vendor or Company, are sent to the contractor upon request from the Resident Engineer or one of his delegates by use of Form OE-53 (Enclo-sure 18). They are sent to the contractors for their information only. If the drawing is requested on a one-time basis only, it will'be stamped FOR I:Jon"ATIE ONLY; if the request is for subsequent changes, the drawings will not be stamped. y) Subsequent changes to these drawings will not be sent to the contractor unicss l Rev. September 11, 107 l
- 3.10 Continued O
kM, requested. All drawings in the contractor's possession marked FOR INFOP'%TIO:: ONLY from this date forward will not be subjected to audit by Company personnel, since these drauings so marked are not to be used for construction. 3.11 Contractor's Field Drawings and Procedures Drawings that are drawn by the contractors onsite (Lift dugs., piping, isonctric, hanger dwg., etc.) are submitted to P G and E onsite office for approval. Thesc drawings are checked by P G and E field engineers or inspectors against the P G and E drawings. They are returned to the contractor with the stamp (No. 6) below noting the appropriate condition of the drawing. 3.12 Contractors Procedures Procedures that P G and E requires of contractors (equipment installation, welding, scid repair) are submitted to the P G and E field office for approval. These procedures are reviewed by the responsibic field engineer or inspector and O stanped with the stamp !;o. 6 below noting the appropriate condition of the procedure. NO. 6 i APPROVAL 4A$ NOTEo) O A =,.... .. e. so ..... O sai.. i. N. ,,,... . ., O a. A . .. O ' a.-... o ,. ... . ;,.. O r. ..a . .... O A =,.. e., C....,. ! a. m ... ro. ..., or - o. . _ PACIFIC G AS & ELECielC CO. o.... C..... i l l l l i Rev. September 11, 107.
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0; ' 4.0 ATTACINENTS . l Encl. 1 ENGINEERING DRANING REQUISITION Encl. 2 FIELD DRAWING REQUISITION Encl. 3 VENDOR ROLODEX CARD FILES Encl. 4 CONTRACTOR FIELE PRAWING CONTROL SHEET Encl. 5 C0'!PANY DRAWING CONTROL SHEET Encl. 6 VENDORS DRAWING CONTRCL SHEET 1 Encl. 7 VENDORS DRAWING AND INSTRUCTION MANUALS RECORD Encl. 8 TRANS5!ITTAL FORM Encl. 9 DAILY LIST OF. NEW AND REVISED DRAWINGS Encl. 10 ON JOB DRAWING' INSPECT;0N REPORT Encl. 11 ENGINEERING DEPAR'DIENT TRANSMITTAL Encl. 12 SKETCH REVISION SilEET Encl. 13 RECORD OF SKETCHES CHANGING ORIGINAL DESIGN DRANINGS Encl. 14 SPEC. AND ADDENDUM DISTRIBUTION RECORD Encl. IS SPEC. CilANGE ORDER DISTRIBUTION Encl. 16 BID LITIO AND ADDENDUM DISTRIBUTION RECORD Encl. 17 FOLLON'-UP ON INCORPORATING DRAWING CilANGES Encl. 18 REQUEST FOR ADDITIONAL DRAWINGS Encl. 19 DRAWING RE1 URN FORM l 4 i o Rev. 6-14-72
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- PHOTOSTAT' PDfNT ONE $1CE ONLY 105 FM MICROFILM
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Ik) UCIIU IERCI 1960 X OFF5ET PRINTING ASSEMBLE ONLY E
- IEGOI 7000 OUT$lCE LETTERHEAD STAPLE ..r- !
s PHOTOCRIPHIC PAPER FURNISHED PUNCH HOLES PHONE RHEN RE ADY
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CATE OELIVER To:
- EITEN510N ROOM NO. A00RE55 -
6-2-72 ' * ' Sco atteche:1 "' 3337 201G '
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QJLNTITT CsG NO. OESCRIPil010F MATERIAL REMARKS ., a 49 h!;33C4-1 ** - 'Dciblo Canyon Sito ' ** " "* OESTP0Y PL ATES '
.......u..:.... 4 :. FILE ORIGINALS i
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RETURN CR!0!W.5 443375-1 443369-a .ms,e , f , . - - L 2: r. u 20lo m : C.nli 4433 5 2 4433 % 2 =,.:,, . . i.# ..o .a w . . .y .Cc~ . ' fA3 ,GO-a 443367-a..a.,,.. ,,e.. w ....u.,,, ..CS31-6E33 443361-2 4332-3 e. rf n.n o - +:e , .- 4433G2-2 44336')-2 .. ., , ,. ' ~' CHARGE TO RESFONSIBILITY CENTER NO. RECUESTED BY AFPROVE0 SV
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22-205 i SENO THEEE COPIES TO P.S.8 E. - ENOINEERING DEPT., RECOROS AND REPRODUCT:CN UNIT
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.XJROI TC00 OUTSICE LEffERhE10 ifAPLE PHOTCORAPH!C PAPER FURNISHED PUNCH HOLES PHONE THEN READY 041E CEttVER TO EXTENSION ROOM NO. ACORESS 0Yk bf,JY 1_/ @ A AV lQh
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QJANilif ctg. NO ' CE SCRIPfl0h 0F' M ATERI AL DE1T80Y PLATES FILE ORICINALS RETURN ORIC'NALS CHARGE TO RESPON518tlTY CENTER NO. RECutSTED ST, APPROVED BY AS-4/9 u)Ef/arrP'
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- EhGlhEERING CEPT RELG,R05 AND AEPROGUCTICM Wai En a ervar # .1
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DIABLO CAI.' YON IfAULING UN.T . . .4 ' ^ Vende'r) ~ D WE66-100-E-07 S N OM* N LA N CE M O) g BIGGE CRAIE RICOI!!G SPEC. 8823 .
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?!. A s ?!OT A P P R OV E D RA.C RETURilED FOR ADDITIONAL CORRECTIONS Oa A CDITIC WAL COPY R.3 s REVISED 8 RESUBMITTED BY PG8E NO.
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O ADDITIONAL COPY OF EARLIER CHANGE REQUESTED A. ADVANCE V AP? ROVED FOR CONSTRUCTION R PRELIMINAR't ggApfyg gg, f+39531 4 ISS'JED FOR BID N.O.S. NOT ON SITE m.mr __ __ . minemmerne . - _ _ er: tru m.-- .-o- u ee na.m _, _ . wn xn =w.amem . . . _ . ,.- . . . ._. __ _ne-mme-- l' Co. Nurabar ' Distribution To pg g g_ 97,,,,$,,7g, l n ygjg " g,,g;gg, Rey Rev Dale Copies of Contractor l p,jnys Date .Ccpics Spec. ' Copics Copics Cop!:s i Date Rec'd Rec'd File Rock Field Rc/ch:d1 l, - No Niade , Trans. Trans. No. Referned Destroyed fi __cn___ k s ri 3 ?? D 2 :'17n 3Mvia I9 3317o ten awa nR?I lnniA a I 4' 's-r .* I or s. , s. m 2. c , n a ., . p -
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DRAWING NO. 1+39531 RACK NOf))fC Company Drawing Control Sheet
( ) , . N.A. NOT APP'D B REVISED A.O S. APP'D ON SITE ' A.S. APP'D AS TO SUt3 STANCE C.F.C. COPY FROM CONTRACTOR S.N. SODJECT TO NOTATION R PRELIMINARY
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. PACIFIC GAS AND ELECTRIC COMPAN'Y.
' General Construction g, f g,yfg Da te .. . 7...../. ... .f.. . 7...f.. ....
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Atiention: . . . . . .O s. n...../.7....M.. .. . . . . . 2 Spe c. No. .. ..u..7.. 3. ..../.... Copies Drawing No. Revision SF Cont. No. . .. Spec.No. No.
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! RETURN ORIGINAL OF THIS TRANSMITTAL DATED AND SIGNED to. l EAlcL osund 'S
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D AI LY LIST OF (v' N NEW AND REVISED DRAWINGS I
- u. :. 19.__ GM-lG7027 H Ci m MCWCAL f.EC IC E SM-W DR AWING DRAWINGS
,A D R AWINGS DRAWINGS D R AWIN G S (TRESLER)
G (FRIEDRICHS)
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(WRIGHTJ (B R A N D) (SPECP) (SPECD (S PEC9. (SPEC 5 m l
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'd' L 1 HAVE NOTED THE ABOVE AND HAVE PASSED IT ON TO MY ENGINEERS ANO If4SPECTORS.
- 2. THE ABOVE PROVIDED SPECS APPLY TO THE REVISION NOTED ONLY.
SIGNED: RESIDENT ENGINEER _~
C DIABLO CANYON SITE g UNIT NO. GM- Ri w , ON JOB DRAWING INSPECTION REPORT DATE OF AUDIT CONTRACTOR SPECIFICATION P.G.8 E. DRAWINGS CONTRACTOR DRAWif4GS ON RK.O-ON CONTROL'SHTS.O ON Ft.0. RK O-ON OF F. RI'. O-O FF. REC O oc or Vcador oc o, vendor CO. or DC.
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co R c" to o of DATE DRAWING
" DESCRIPTION to$ raSYo of REMARKS Nbin REMARKS NUMDER Olock n9I?in Bl5ck nN?io .
i l t I COMMENTS: (Explain any discropancy and correctiva action taken) ' N_OTE: V'/endor dwgs. Only give the table of change rev.as well as tb-0.C. no. rev. . CalG 'Or Of fice Engr. COPlES TO: Resident Engr.-Oualit trance a Contractor. OE-l ( REV.11- 2 2-71 ) SIGNED: _, , , , , , , ,
.y 16-24s' mu 3-7-70 PACIFIC CAS AND ELECTRIC COMPANY .)
= Units 1 and 2 RECORD NUMBER DWG. LIST - MANUFACTURERS DRAWINGS g JOD Dinblo Canynn 4R- 22-A F.700-RA EMM SPEC. 8700 SUPPLIER _ Westinnhouse ENCR. J nor'.in RECORD NO. 663280 DESCRIPTION Turbine - Generator SYSTEM Ceneral FILE NO. / *MN-DW C *S. EQU1PMENT DATE AT T 'D. S H.# n ry STAT uS D AT E S QTY. M ANuFACTURER TITLE MFR.NO. P E V. DIST R.
# g RECElvED 7244S /0 1" Dinmeter Dowel Enc}osure N 16 RETURNED Mestinrhouse 274A190 /
9 a RECElvro 7 '/ - 70 /0 Loncitudinal Section Throunh 'furbir
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i 17 3 0- 'Efi issi 0 t /- su- v <r a 720J1/.5 18
/ g" RECEIVED 7-76 6 /0 n
Anchor and Alinnr.ent Features 722J46g 2 7-/v-4 7 RErunnED nECEIVED ~ nEIunND' 19 H RECEIVED 7- N-7/ /0 'evelinrr T Fentures r, Generettor AB 20 8 C RETuanEr m " 11 t2 458('D74 4 I b RECcivED ' 7 ?/.t.9 /9 n Tent Connections for Fiel fest, Sh. I of 2 .
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21 RETurnrD /e- rg.g L. p. 725J191 /
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n Tent Cnnnactions for Field Tent I,. F. Sh. 2 of 2 j // 5- 20 Is E T u'iN rD {^. 2 2. /. 9 725J191 g ' nECEivED 7.p/-/.</ /9 Te, t Cnnr.ec t i nan rnr Pic]d Test H.P. 23 / IRETunnEn /4 7:.m g 'RECrivrn l'/ P71- /d
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29 b g RECrivro RETunNED
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Instruction for Field Asnembly or Multi-Ploce Stat or Unit 1 20855A _ /2 -/7 ~// 8 RECElvE D /d-X/-76 <0 Turbine Outline Sunnlements-Desinn 30 2 RFrunnro m " Noten Unit 2 401A478 2-
.STgTM D R AWIN G DISTRIDUTION AND ACTION ,_ '{ t,* . .)
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l RECORD OF S/WTCHES CHANGING OR/GINAL DESIGN Dl?.oWINGS I' G
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D/ABLO CANYON UNIT-l&2 3 DR AWING ~ No. f;o. R EC'D COPIES TO DATE AD 2 OHG DATE COPIES TO
- T TLE P.G. O E. TO ORIGi! /
tio. R EC'D. MAIL CONTRACTOR ENGRS. DRAWL;;C Lil:E l I l l l I e 1 "'s.
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E N T R A U e T D E R O ) T E R D U E T N A . G N I G S I S S ' ( D A R O C E R D E E N T G A I S N .D S O A _ I T ' U B I R . T IS D M U D E H C
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_ _ _ _ ._ [ _ _ D T / 2 _. D T 1 . _ . A A l I l 0 _. l 1 _ _ D S M D _ _ _ _ t_ _. _ . N U _ _ A 8 _ D _. l N . . E 7 ._ _ _ l D _ _ O D C _ H A l { T l 5 l l,
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1 l 4 _ 3 _ D ll 5 l 3 ' l 2 _ N e# l 1 ._ O D 6_L E TH V C. T A E I i E I P D L EC - C_ R G S A R m P Y E P B 0 2 3 4 S 7 a 9.02 1 2 3 __ 3 M I 3 5 G 7 8 9 2 2 2_ u 1 O l 1 I 1 I 1 1 1 C U N .- E G
l 4 PACIFIC GAS /ND ELECTRIC COMPNAY STATION CONSTRUCTION DEPARBtEhT DIABLO CANYON PROJECT DRAWING FOLLON-UP NO. - I '
'l ; Follou-up on Incorporating Design Questions, S. F. Telephone Calls, and on All Types of Sketches on Design Drawings.
TO: M.11. CllANDLER/R. S. BAIN .
/J. W. WOODNARD
. DATE FROM: W. R. !!ERSEY j . DIABLO CANYON SITE SPECIFICATION NO..
DRAWING NO. CIIM:GE has been issued. This drawing does not incorporate the changes as shown in sketch (s) and/or telephone conversations or design questions as listed holow. PLEA,SE EXPEDITE! DATE SKETCll NLD1BER, TELEPH0:!E CONVERSATIONS, OR DESIGN, QUESTIONS 0: - 1 i l - SIGNED (Resident Engineer) l DATE REPLY a
+
SIGNED cc:hTU!crsey (Design Enginecr) File j G-3G (Rev. S-14-7I)
Di AB LO CANYON GM. STATI O N CON S TR U CTIO N 1 l REQUEST 1 OR Al?ClT/CNA!. DRAM!iNGS DATE S P EC. No. l l PLEASE TRANS!.ilT THE FO LLOW! N G... . l P G 5 E D37. ISAMUALO O VEG000 DRU.O OTMER. O 1
! TO-1 I
1 h,) . l l l l l l l i B O ' DISTRIBUTION O THIS TIME ONLY S/6 NATURE D CONTINU ALLY O E.53_ D ATE 9 _7 - 7 I on-53 (9-7-7o _ __ [Nd 2 0.rva6 6
DIABLO CAFJON PROJECT DIABLO CAIRON PROJECT I
. DRAT /IF:G R5: TURF! FORM DRAUING RETURIT IVRM DATE DATE j TO:
I
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The drowing !!o', you ,The drawing No, you presently have checked oht is void presently have checked out is void es of please return as of please return irunedia tely.. imecdiately. PRINT ROOM PRINT. ROOM Signed: . Signed: - OE 24 (3 25 70) OE 24 (3 25 70) DIABLO CA!20Ii PROJECT DIABLO CAIROIT PROJECT DRA?lII:G RE?UR I FORM pggg pgggg gpg DATE DATE TO: TO: The drawing !!o, you The drawing No.
- you Josently have checked out is void '
presently have checked out is void ca of 'please return as of Please return ic=ediately. insediately,
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PRIUT ROOM . PRINT ROOM Signed: Signed: OE 24 (3.,25-70 ) . OE 24 (3 25-70) ,
'DIABID CAIUOff PROJECT DIABLO CA! EON PROJECT DRAV;II:G RETURN FORM DRA71TNG RETUR'i FORM DATE DATE TO: TO:
The drawing No, you Tt? drawing No, you
.prasently have checked out is void presently,1; ave checked out is void sa of please return as of Please return
(' p:cdiately, immediately, v PRII.2 ROO!! PRI.T ROOM Signed: Signed: 02 24 (3-4 -1u> 05.24 (3 c 70) y 7 g ,(,, y ajg i
l l O i i PACIFIC GAS AND ELECTRIC COMPANY t
! DIABLO CANYOU PROJECT i
DRAWING CONTROL PROCEDURE 1 I O Please insert the attached revised pages 3, 5, 9, 16, 17, 18 into your Drawing Control Procedures.
- Indicates Revision Approved 9// f. & Y.hL/ &
M.R. TRESLER Project Superintendent Date Revised JULY 28, 1978 O l
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f f i. PACIFIC GAS AND ELECTRIC COMPANY Diablo Canyon Site
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DRAWING CONTROL PROCEDURE i.. 1.0 SCOPE The purpose of this procedure is to establish and prescribe the manner in which all d-awings are to be received, filed, and distributed, as well as to institJte the necessary safeguards to ensure that the latest revisions of all drawings are exped'tiously transmitted to the contractor, and to have same available to com-pany ; ar onnel. The details of performing this procedure will be ' spelled out hereir., along with listing and describing the records that will be maintained by the Office Engineering staff. This procedure will be constantly subjected to revicw and will be revised accordingly when changes are necessitated. 2.0 0_R_IGIN OF DRAWINGS AND SPECIFICATION ADDENDA AND CHANGE ORDERS
' 2.1, Origin of Drawings Drawings originate from the design engineer in reproducible form. After a draw-ing is approved for construction by the engineer it is returned to Central Files with a requisition for the necessary quantity of prints and reproducible prints, to be sent to the job site. Enclosure #1 shows a requisition as prepared by the Engineering Department. Prints may be requisitioned from the field in the fol-lowing manner. A requisition will be made out and forwarded to the Manager, Station Construction Department, in care of R. S. Bain. He will then draw out the tracing and have the required number of prints reproduced and then forwarded to the field along with a copy of the requisition. Enclosure #2 depicts a req-uisition originating from the field.
2.2 Origin of Specification Addenda and Change Orders 1. l Addenda and Change Orders originate in the Engineering Department. Once an addenda cr change order has been written, it is reproduced to the required quan-tity and sent to the Manager, Station Construction Department. One copy is 1
. Rev. September 30, 1975 L_ . . . _
- - - - - - - - - - - ~
.I .
2.2 Continued retained for the office file and the remainder is sent to the Project Super-intendent. Additional copies of the addenda or change orders can be made on
. the Xerox.
L 3.0 APPLICATION 3.1 Drawing Control Records 3.1.1 Company Drawing Control Sheets (Enclosure #5) These control sheets will be maintained for each company drawing received at the site. On this sheet is indicated the current information concerning dates, quantities, distribution and filing information, of all revisions pertaining to that drawing. The appropriate rack number or numbers for the drawing will be indicated in the lower right hand corner of that sheet. An asterisk and stamp stating approved for construction along with color highlighting will be used to indicate Approved for Construction drawings. ' 3.1.2 Vendor Drawing Control Sheets (Enclosure #6) A sheet will be maintained for each vendor drawing received at the site in the same manner as the Company Drawing Control Sheets, except that color highlight-
; ing will not be used.
3.1.3 Vendors Drawing Control Sheet for Contractor Field Drawings, etc. (See Enclosure #4) This form serves the same function as the company drawing control sheet except that it is used for various contractor drawings and procedures. The fonn pro-vides for following the individual drawihgs and procedures through their approval stage as well as distribution. - t i 3.1.4 Vendor Rolodex Card or Control Sheet Files for Drawings without Record l Numbers (See Enclosure #3) l A card or control sheet will also be maintained for each vendor drawing that is not accompanied by a record number. Each drawing will be recorded by vendor O' drawing numbers, specification, structure or area, and as a last resort by
. Rev. September 30, 1975
-= , _ , _. . _ - . _ - _ _ _ _- l
v ndor name. All of these drawings are filed in a miscellaneous file by spec-cification. 3.1.5 Vendors Drawino and Inspection Manuals Record (Enclosure #7) On this fom is maintained all the infomation pertaining to vendors drawing and instruction manuals with cross references to the various identification numbers as indicated. The key feature of this fom is that it will be filed by type of equipment rather than numerical sequences. This will provide a system that allows an engineer or inspector to locate drawings.and/or manuals by type of equipment without requiring knowledge of either record or drawing number. 3.1.6 Transmittal Forms 61--9699 (Enclosure #8) & 62-5537 (Enclosure #8a)
- Fom 61-9699 will be used for transmitting all drawing, except "as-builts" to Engineering. Fom 62-5537 will be used to transmit "as-builts" to Engineering.
M 3.1.7 Daily List of New and Revised Drawings (Enclosure #9) Each day the print room personnel will publish a listing of all company and vendor drawings received that day. This listing will also include sketches,
** and DCR's that constitute a drawing change.
, These company drawings received with a notation, " approved for Construction,"
" Issued for Fabrication and Installation, " Approved for Planning and Material Proctirement, "etc. will be noted with an asterisk on the listing. It is the responsibility of the Resident Engineer to provide the specification number for these drawings and return the signed fom (Enclosure #9) to the Office Engineer each day.
3.1.8 On Job Drawing Inscection Report (Enclosure #10) This report will be completed by company engineers, and inspectors at random as directed by Resident Engineers. The report, when completed, will be distributed as shown on the fom. Audits will be performed as often as necessary depending on the number of new drawings received on the Project, but as a minimum an audit will be made each week. ! O l V l REY. JULY 28, 1978 i I
1 3.1.9 Receival of Drawings All incoming drawings, specifications and manuals are delivered to the print room directly before any distribution is made. One copy of all sepias without prints received will be reproduced immediately and placed on the inspection table. At the same time the balance of the drawings are being spread out on the layout table, sorted, counted, and the- date stamp placed on each one. Drawings received l 1 from vendors and contractors will arrive with several copies of an engineering department transmittal attached (See Enclosure #11 for sample). This transmittal i will have the vendor's name, purchase order number, record number," sheet number, i and description on it. 3.2 Distribution and Filing 3.2.1 Information will be provided regarding the number of copies of company drawings to be provided each contractor. Company drawings which are identified as showing work which is withheld from the contractor will not be distributed and a note to that effect will be entered on the drawing control sheet. Copies of vendor's and contractor's drawings will be transmitted to c3ntractors on the job site when requested by the Resident Engineer concerned. A letter of trans-mittal (Fcrm 61-9699, Enclosure #8) will be made up for all drawings transmitted to concerned contractors at their job site headquarters. An original and two copies of the transmittal are prepared, and third copy retained on file which serves as a basis for determining what transmittals have not been returned and signed. The third copy is pulled from the file and destroyed when the signed S transmittal is returned the same system will be used for fonn 62-5537. 3.2.2 At the beginning of each week the Active File is checked for outstanding
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I transmittals that are unsigned for more than a week. A xerox copy of these transmittals will be sent to the original addressee with a statement as follows: According to our records we have not received a signed copy of this form, due to loss or mix-up en route. Verification of receival is necessary to complete our records. Please check your files and return O this signed. Thank you for your cooperation. 3.2.3 When drawings are received, the following steps are taken: Rev. March 1, 1978 b
O 3.2.3 Continued b A. They are all date stamped B. Drawings are separated into four categories: Contractor, rack, file and table copies. C. All drawings are recorded on the control sheets. D. One copy of each drawing will be placed on the racks provided for each category. All superseded drawings will be removed from filing cabinets and racks and de-stroyed, except the reproducible, which will be marked VOID - FOR REFERENCE ONLY and filed separately for possible future reference. In the event no reproducible is on file, a print will be kept. When all superseded drawings are removed from files and racks, the remaining new copies can be folded, marked with number and revisien on the top right hand corner, and filed. 3.2.4 For drawings received from vendors and contractors, a divider with the drawing number will be inserted between each new drawing in the file. All of these drawings will be filed behind the identifying divider. Void drawings will be processed as with company drawings. A print also will be retained for future reference if there is no reproducible available for that purpose. , 3.2.5 One copy of each approved drawing received each day will be placed on the provided inspection table for tne infomation of company engineers and inspectors.
- All' new drawings, drawing revisions, sketches, as kuilts and DCR's received each day will be listed on the DAILY LIST OF NEU AND REVISED DRAHINGS, which will be provided to each Res. dent Engineer, indicating what drawings have been received pertz'ning to their respective areas. The original of this fem will be returned
! at the end of each day to the Office Engineer, signed by the resp'onsible Resident l Engineer, indicating that he has seen the list of new drawing received and passed same on to his engineers and inspectors. After 48 hours, clock time, the 1 drawings will be removed from the inspection table and placed in the file. 3.2.6 All drawings taken from the files will be signed for by the individual requesting the drawings (see 3.5.4 also). This accounting record will be main-tained on 6he out card filed with the drawings. It is the responsibility of the REV. JULY 28, 1978
3.2.6 Continued individual signing for the drawing to return same when requested, or when he i no longer has a use for the drawing. , 3.2.7 Drawings issued as " sets" (i.e. piping schematics, instrument schematics, electrical schematics and arrangements in 11" X 17" and 81/2" X 11" size), will 4 be signed out as a set, and will be returned complete. When revisions to drawings issued as a set, are received, they will be processed as previously described with the following exceptions: (a) 11" X 17" size copies of electrical schematics, logic diagrams, and electrical arrangements will not be" placed on the
, table for inspection. (b) Distribution of the revision wiil be made automatically 3
to all P G and E personnel on record. NOTE: Processing of superseded drawings j-issued as 11" X 17" size " sets" is described in sub-paragraph 3.4.1. 3.3 Inspection Procedures All the procedures up to this point provide the necessary documentation to ensure that only the latest revisions of drawings have been transmitted to the contractor and company personnel. The procedure for recalling superseded drawings from j company engineers and inspectors is covered in paragraph. 3.4. Since the contrac-tor on the job site in most cases will be provided with reproducibles of drawings
- transmitted to them, it therefore becomes incumbent on the company inspectors or engineers to verify on .a weekly basis that all contractors and subcontractors are i
using the most current revision of a drawing. This is accomplished by various inspectors /angineers performing an inspection of prints being utilized for all active specifications. A minimum of six, prints for each unit where work is being performed will be compared to the Drawing Control Sheets to verify that the draw-ings are current. If a specification has fewer than six drawings, then 100% 'of the~ diawings are re'vTsed. ~ Those drawings which are reviewed shall be listed by drawing and revision number on form OE-1 "On Job Drawing Inspection Report" (Enclosure #10) as well as the latest revision shown on the P G and E Drawing Control Sheet. Any discrepancies between the two shall be noted in the comments 6-Rev. September 1,1976 i
. portion of the report as will the corrective action taken. Although all draw-ings are subject to audits, those drawings used for work being presently per-formed or to be performed in the future, shall receive first consideration for review. In the event that no work is to be perfomed on a specification for a consideraole length of time, fonn OE-1 shall be submitted with " Discontinued -
1 No Work" written in the comment section and the drawing section above lined out. i Before work resumes on the specification, the drawing inspection program shall be reinstated to assure the latest drawings are being utilized. When the work on a specification is complete, an audit report shall be submitted' stating that
! the work is complete and no further audits will be performed. All drawing audits shall be submitted to the Resident Engineer by noon on Thursday for sub-sequent distribution to the Contractor and Quality Control. A record of all audits submitted will be maintained by the Quality Control Department.
3.4 Superseded Drawing processina In paragraph 3.2.3 it was stated that superseded drawings will be withdrawn from the files and destroyed, with one reproducible or print marked VOID - FOR REFER- g_ ! ENCE ONLY and retained for possible future reference. Any drawings that have I field. notes marked on them will be taken to the respective engineer to see if it warrants an as-built drawing or are the notes worth saving. If the notes are to be kept, the drawing will be stamped and handled as above. When superseded draw-ings are removed from the file, any that are signed for on the out card will be recalled from the individuals by the use of fonn OE-24, Enclosure #19. All draw-ings recalled will be returned to the print room within one week of the date on the OE-24. If any individual desires to have a copy of a VOID drawing, a. print will be made and entered on a record that is maintained in the print room. In this manner all copies of VOID - FOR REFERENCE ONLY drawings in the hands of company personnel will be accounted for at all times. Superseded drawings in tne hands of contractor personnel will be controlled by the exhaustive inspection procedures out-lined in paragraph 3.3. l l 7-Rev. September 30, 1975
3.4.1 Superseded Drawings (11" X 17" and 81/2" X 11" sets) (G) In sub-paragraph 3.2.7 we described the special procedure employed for processing drawings issued in 11" X 17" and 81/2" X 11" sets. The processing of super-seded drawings in these " sets" will be the responsibility of the respective Resident Engineer. He will issue instructions and develop a procedure to assure that the engineers and inspectors under his direction are working from the latest
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revision. 3.5 Processing of Sketches and/or Partial Changes In order to expedite necessary design changes, or to make small chinges in draw-ings, 81/2" X 11" Revision Sheets (sketches) will be utilized. (See Enclosure
#12 for sample). These sheets may be transmitted by company mail or, where expediency dictates, by telephone telecopier.
3.5.1 Receival and Distribution When a sketch, which constitutes, or is suspected of constituting a drawing n change, is received, it is taken to the respective field engineer or department (] liaison man for verification that it indeed is a drawing change, contains the proper approval signatures, and whether it is to be distributed or held. Before distribution is made, the Diablo Canyon sketch stamp (Fig.1) is applied. Then a sketch number (indicating the next revision of the drawing to be issued) and a small alphabetical letter (ir.dicating sequential sketch issuance) are assigned. In some cases, the Engineering Department has already assigned a sketch number and letter. If the assigned number and letter agrees wita the print room records, it will be entered on the sketch stamp (Fig. 2). When the sketch number assigned does not agree with print room records, or when it is missing entirely, the print room personnel will assign the sketch number and letter. An asterisk is added to the sketch to distinguish numbers assigned on the job site from those assigned by Engineering (Fig. 3). Rev. September 30, 1975
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SHI. OF ^ r, .; , a SN. He. AS$1GNED ON $!TW , Sketch numbers are logged on fom OE-2, Record of Sketches Changing Original Design Drawings, (Enclosure #13), then distribution is made. . ECO's, Memo's and Telecons which constitute a drawing change will be handled in the same manner as a sketch. . Sketches will be distributed to all contractors who are recorded as having copies of the drawing being affected by the change sketch, unless directed otherwise by the responsible Resident Engineer or his delegate. One copy of the sketch will be attached to the rack drawing, one copy given to the responsible department, and the original will be retained on file in the l print room. It is the responsibility of the Field Engineers and Inspectors to i b("N make certain they are working fron the latest revisions to the drawings in their possession. Phone calls, which constitute a drawing change, will be identified as to whether they are Class I or Non Class I. When the required stamps and signatures are affixed to the telecon, they will then be assigned a sketch number and be processed by drawing control, as any other sketen.
'3.5.2 As-Suilts g
The changes to drawings or sketches showing "as-built" changes to be made to other drawings will be initiated by the $ngineer of Inspector in charge of the individual structures or systems. They are" responsible for marking up the print with the proper color pencils, (green for deletions, red for additions), giving all dimensions and sufficient information to adequately show the actual "as-built" O REV. JULY 28, 1978
1
, 3.5.2 Continued :
condition of the structure, system, equipment, etc... "As-built" sketches are , confined to 81/2" X 11" size xerox copies whenever possible. , When the Engineer or Inspector completes an "as-built" drawing, he will stamp the sketch or drawing in red ink and fill out the blanks per the sample shown below, (Fig. 4), before turning it into the print room for distribution. DIABLO CANYON AS BUILT DWG No. 596YJ~3 SIGNATUREh h nATE Y -#- T f Fig. 4 The print room will assign a sketch number (as described in paragraph 3.5.1) and reproduce the number of copies required for distribution. The copies will be given to the draftsman to be marked up in the same manner as the original. When the draftsman completes the changes to the copies, he returns' them to the print room for distribution. l Distribution of "as-built" sketches are made as previously described in para-graph 3.5.1, except there is no distribution to the contractors unless requested to do sd by an Engineer or Inspector. In the case of extensive changes, where a full sized drawing is marked up, only the original and one copy will be made. The original will be retained in the print room and the copy will be sent to the Engineering Department for incorpora-tion on the next revision. 3.5.3 Approval of Drawing Changes 4
- Approval of drawing changes will be in accor~ dance with PRC 11.
YliO184.a45
,5&libi pHtwdf 4 '. i Gid t&iG LJ, ~P lsldlld$J ct!,a e/wpf Rev. April 20,19,
t 3.5.4 Incorporation _ When a new revision to a drawing is issued, the print room personnel will detach all sketches, as-builts, messages, and phone calls from the o'id revision and reattach them to the new r'evision on the rack. A second copy of the Daily Drawing List will be given to each department, indicating to them by color high-lighting the drawings having attachments that require incorporation. The respective Field Engineer will check all of the drawings on the list that pertain to his assigned area, for incorporation of the attachments. Then he will CAREFULLY detach the sketches, San Francisco phone calls and as-builts, that have ; been incorporated and take them to the print room. There, he will stamp the original sketch in red ink and fill out the blanks per the sample shown below. , I i l l O INCORPORATED ON DWG. i i DWG. No. s m e CHG..s ! DATE s_ u 19 n l
' SIGNED e v
um i < Fig. 5 ! l
- The incorporated sketches will be removed from the current sketches and will be destroyed after the date the sketch was incorporated on the drawing is i
f filled in on the OE-2 fom. Enclosure #13. (
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Rev. liay 10, 1978
3.5.4 ' Continued - Lt_is_Jnandator.y_that_drawinas_be_ checked far incorooration_bv a. Fiel.d..Engi_neerf_ Insnector_within _2 weeks _of_on_ site _recaint_of JLnew_reyision. . Periodic review of the current file will insure that incorporation is being accomplished within the two week period. 3.6 Processing of Drawings Received for Approval y Drawings submitted to the company Field Office for approval will be processed as described in the Quality Assurance Manual (PRC-ll, paragraph 3.3). 3.7 Process of Specifications, Lithographic Sets and Addendums All specifications received will be accounted for on the Specification and Addendum Distribution Record (Enclosure #14). A specification will be in the Specification Correspondence file or assigned to an individual by initial. When addendums are received they are issued to the appropriate holders of the proper Block on the form. Specification Change Orders will be processed using the fonn shown in Enclosure #15. Lithographic sets and addendums thereto will be processed as aboye using the form shown in Enclosure #16. 3.8 Aperature Card Listing This listing is provided on a biweekly and monthly basis by City Records Depart-ment. Upon receipt this listing will be checked by the print room personnel to verify that we have received all the drawings and latest revisions listed. If there are any deviations noted a xerox copy will be returned to City Records Department for their action. , 3.9 Method for Checking Validity of Vendor Drawings Used for Field Construction When Engineer or Inspector receives copies of the vendor drawings from the contractor, he will stamp them, COPIES RECEIVED FROM CONTRACTOR. O
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Rev. October 5.1976'
. . . . . - _ ~ .s 3.9.1 The Engineer or Inspector will check the contractor's copy against the on file record copy (which will have either stamp No.1, 2 or 3 affixed, PRC-11).
No. 1 No. 2 PACIFIC C'sS l.D ELEC1RIC CO. PACIFIC GAS & ELECTRIC CO. AFFT///ED FOR C03STWCYlCH APPROVED FOR RECORDED CONSTRUCTION DEPART:El.T OF D:3t!:EERID ENGlHEERING DEPARTMENT l BY DATE No. 3 PACIFIC GAS AND ELECTRIC CD. 7 DEPARTrENT OF ENGINEERING l d Approved As To substance I3 Subject to Notations Shosn , O Not Approved O Furnisa Revised Drawings.for Approval C1 F u r n i e h rinal neneines end senendunsheng l Kef er to attached transmittel dated , By: Date: Approval does not relieve supplier / contractor of responsibility for correct fabrication and compliance with specification and/or purchase order. I If the contractor copy agrees with the record copy, or if it falls within the per-mitted use (as outlined in PRC-ll), he will apply stamp No. 4. Stamp No. 4 is ap-plied in black ink and signed by the Resident Engineer or his authorized delegate. No. 4
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A F ? D 0 V E D F O!I !!!S T A L!. AT10!! BY: DATE: 3.9.2 If all items are installed and the pour is ready to be made, but no final approval drawing has been received on site, the Resident Engineer or one of his delegates may seek written approval to apply stamp No. 2 PRC-ll. l l l Rev. September 30, 1975
,- w 3.9.3 When the Engineering approved copy of the contractor's drawing arrives on site the approved on site copy is checked against it. If both drawings con-fom to each other, the Engineering approved copy should be stamped with stamp No. 6 below, with A.0.S. copy to be destroyed.
If the two drawings conflict, the Engineering Department should be notified and either the Engineering approved copy voided or a solution to the conflict pre-sented by the Engineering Dep'artment. No. 6 , AGREES WITH APPHuvED ONSITE COPY INITIALED DATE 3.10 Information Only Drawing
- These drawings, either Vendor or Company, are sent to the contractor upon request i
v' from the Resident Engineer or one of his delegates by use of Form OE-53 (Enclo * ' i sure #18). They are sent to the contractors for their infomation only. If the drawing is requested on a one-time basis only, it will be stamped FOR INFORMATION ONLY; 1f the request is for subsequent changes, the drawings will not be stamped. Subsequent changes to these drawings will not be sent to the contractor unless l requested. All drawings in the contractor's possession marked FOR INFORMATION l ONLY from this date forward will not be subjected to audit by Company personnel, since these 'd rawings so marked are not to be used for construction. 3.11 Contractor's Field Drawings and Procedures Drawings that are drav a by the contractors on site from approved design drawings, (lift dwgs., piping, isometric, etc.), are submitted to P G and E on site office for approval. These drawings are checked by P G and E Field Engineers or Inspec-l tors against the P G and E drawings. They are returned to the contractor with the stamp (No. 5) below noting the appropriate condition of the drawing. v Rev. September 30, 1975
,_ 3.11.1 Hanger drawing are original design work and require stamp fic. 2 per k,. PRC-ll.
3.12 Contractors Procedures . Procedures that P G & E requires of contractors (equipment installation, welding, weld repair) are submitted to the P G & E Field Office for approval. These procedures are reviewed by the Responsible Field Engineer or Inspector and stamped with the stamp No. 5 below noting the appropriate condition of the procedure. No. 5 . APPROVAL (A5 NOTED) [ A; proved as to Substance
; s nect o notat.co. ss ..
C *+ii ?; *,t 6,"? 2 a . .seu c : s...u neau.,*a
- C Fura e 'cre : ..c:a s 2 A: ; s. 3 I. e Constr.
..a ~ . . .e p 87, Oate A 116 CA$ & CCTMC C3
" JClO CJey33 3.13 Westinghouse Engineerino -Chance flotice (ECil)
Upon submittal of an ECN for approval, the print room personnel will reproduce one copy "For Information Only" and retain it until the original is approved. The original will then be sent to the' Engineering Department for approval. When the ECN returns approved, it will be given to the respective Resident En-gineer to read and sign. He will thqn return it to the print room for distri-bution. , X 3.14 flinor Variation Design Change Reouests and Desian Change Notices (DCRs f DCNs) 3.14.1 A MVR may be used to document the on site resolution of a Class I construc-tion interference. The respective Resident Engineer will prepare the MVR and
]J attached sketches with sufficient detail for Engineering review. The dispo-sition section will be stamped "As-Built" prior to turning the MVR into
-15 REV. JULY 28, 1978
3.14.1 Continued Quality. Control for distribution. At the discretion of the Responsible Resident Engineer, these drawing departures will be handled in one of the following two ways: (1). The i1VR document package will be kept intact and Quality Control will forward one copy to the print room for attachment to the referenced rack drawing "For Infomation Only." Additional distribution will be made as indicated in the upper right hand corner of the As-Built MVR coversheet. (2). The MVR attachments only will be processed through drawing control as "As-Builts" and will reference the , applicable As-Built MVR number for authorization. In this case, it is not necessary to attach a copy of the As-Built MVR to the rack drawing for infomation only because the As-Built sketch will be attached in its stead. The MVR, or sketch'in review by Engineering, may instigate a femal drawing change. ( 3.14.2 Design Chance Recuests (DCR's) @ GCR-12 establishes the responsibilities and Procedure for implementing the use of DCR's. Drawing control is responsible for processing and control of DCR's. This will be accomplished as follows: (1). An on-site DCR log sheet (Enclosure #17) will be used and in order to identify and control them, the same numbering system employed by engineering is established, except the letter following the unit identification will be "G" instead of "E". This numbering system has been established by the nuclear Project Engineer's office and consist of the following: Diablo Canyon Unit 1 DCl-G-g-001 2DC2-G-j-002 I Unitl&2 DCO-G-M-003 o a , General Constructior Civil Discipline
' ' I N Electrical Discipline I
, Mechanical Discipline Sequential flumber From Site REV. JULY 28, 1978
(2). Upon receipt of the DCR Drawing Control will check to insure that the appropriate resident Engineer has si'gned and it has the necessary, information. The next sequential number, with the appropriate discipline, will then be assigned and recorded on the log sheet (Enclosure #17) and the DCR. The required copies will then be made and distributed and appropriate entries made in the 109, a DCR initiated by Engineering will be logged on enclosure 21, and appropriate dis-tribution made. (3). When the approved copy is returned to the site,
, the applicable log entry will be made a'nd apprp-priate distribution made.
3.14.3 Design change Notices (DCN's) When a DCR has been reviewed, coordinated and signed, by the appropriate engineering discipline, it becomes a DCN. When a DCN is received the appropriate entries will be made in the applicable log sheets (Enclosure 17 or 21) and distribution made. O l O e i ((() i _17 \
4.0 ATTACHf1ENTS Encl. 1 ENGINEERIfiG DRAWING REQUISITION , Encl. 2 FIELD DRAWIf!G REQUISITION Encl. 3 VENDOR ROLODEX CARD FILES Encl. 4 CONTRACTOR FIELD DRAWINGS AND PROCEDURES (0E-55) Encl. 5 C0itPANY DRAWIfiG CONTRCL SHEET (OE-7) Encl. 6 VENCORS DRAWIf;G CONTROL SHEET (OE-8) Encl. 7 VENDORS DRAWING AND INSTRUCTION MANUALS RECORD (0E-29) Encl. 8 TRA!!SMITTAL FORM (61-9699) Encl. 8a TRAtlSMITTAL FORM (62-5537) Encl. 9. CAILY LIST OF MEW AND REVISED DRAWIfiGS (OE-6) Encl. 10 Of JOE DRAWING INSPECTI0li REPORT (OE-1) Encl. 11 ENGIflEERIt!G DEPARTMENT TRAf;StilTTAL Efici. 12 SKETCH REVISION SHEET Encl. 13 RECORD OF SKETCHES CHANGIf G ORIGINAL DESIGN DRAWINGS (0E-2) Encl. 14 SPEC. Af;D ADDENDUM DISTRIBUTION RECORD (DE-ll)
. Encl. 15 SPEC. CHAf;GE ORDER DISTRIBUTION (0E-12 Encl. 16 CID LITH 0 AND ADDENDUft DISTRIBUTI0ft RECORD (0E-13)
- Encl . 17 DCR LOG SHEET" Encl. 18 REQUEST FOR ADDITIONAL DRAWIllGS (DE-53)
Encl. 19 DRAWIfiG RETURfl FORf1 (OE-24) Encl. 20 RECORD OF SAN FRAliCISCO TELEPHONE CALLS (G-2)
- Encl. 21 RECORD OF SAN FRAf!CISCO TELEPh0hE CALLS (G-2)
O REV. JULY 23, 1978
SEEU ' w I l_ '
<O
.>r 7,G.w..E..
m 4613.. (,,j REQUISITION FOR REPROGRAP!'IC WORK 00 NOT WRITE IN THIS SPACE AUTHORIZED BY: DEPARTMENT RESPONSIBILITY CENTER NO. LF. Hall /V. Su=ers Desisen Draftine 22-363 h r.-i 19&OR M A199 W ehanfral n iTra 9_1R.7C 8tNDERY PHOTOCRAPHic MICROFILM WHITE PRINT / XEROX OFFSET PRINTING C OFFSET PRINTING b COLLATE $ RIGHT READING C 1EMM MICROFILMING C
, WHITE PRINT
. SEPIA O PAPER FURN!SHED O PUNCH HOLES O REVERSE READING O 35uu utCROPtLMiNG _
XEROX PRINT ONE SiOE G STAPLE (St E SILVER FILM O tosuu u CROFILMING C I Finisned Sue O PRINT 8ACK TO 8ACx 0 FOLO - '- O WASHOFF FILM O 35MM APERTURE CARD [_ FOLO TO O PAPER COLOR O TRiu TO O KPs PAPER O 35MM OUPLICATE PAPER TRANSPARENCY C APERTURE CARO L STAPLEIS) O SPECIAL PAPER O HOLES O COPY SIZE CLEAR FILM C ' 16MM FILM PUNCH COLLATE O 84X11 O ti x 17 O SCREENED IMAGE C PHOCESSING ONLY C, 16/35MM CIAZO PRINT As PER SAMPLE O ~ OUPLICATE ROLL _ 16MM CARTAsOCE LOAD CNLY (, 3M O KCoast O i . l l ! l .. L
- DESCRIPTICN 'OF WORK i
(Cooyright Material Cannot 3e Reproduced Without Perrnission of Copynght Holder) DESCRIPTION OF ORIGINA L NO. ORIG. t NO. OF COPIES l ORAWING NUMBER l 11 i 41 h 049308-10 9/84 Diablo Canv0n P & M Seismic Restraints Area G & F 18 41 i 049310-10 6/,37 Units 1 AISo area F l i ! i i I l i I , I i i l i : i l I m---,. - - - I 4 1"I C.L C 1 \/ C L) SIAIM!i CCli3IEliCTC.'i DEPAliTME!il l ( l l l l - --- ,- ____ g rLu 4U Ds3 ( Pt 9Mt e n a .m n r e anr o SPECIAL INSTRUCTIONS I Please return by 2-20-75 Thank You #ntuLU bNl i Uii Qi!L l 4 l l l RETURN ORIGINAL TO: ! NAME: A.R. Sch:2idt RECORD FILES ROOM
**
- RETURN NEGATIVES A00RESS:
. _ _ _. _ _ _ _ ____ _ = _ _ ___. _ _ __ _ __ _ _ _ _ _
PHONE WHEN READ 1 DELIVER TO: As Noted (see attached) EXT. _ DEPARTMENT: DIVISION: l l ROOM: MAIL WHEN READY l ADDR ESS:
.. .tn2f8soilE%"
Pes.nu G w,,E,, qa r ; a b '( '{ D , REQUISITION FOR REPROGRAPHIC WORK . DO NOT WRITE IN THIS SPACE AUT'.iORIZED BY: DEPARTMENT RESPONSIBILITY CENTER NO. C. K. MAXFIELD G.C. 03-419 - l WHITE PRINT / XEROX OFFSET PRINTING BINDERY PHOTOGRAPHIC MICROFILM l WHITE PRINT % OFFSET PRINTING O COLLATE O RIGHT READING O 16MM MICROFILMING CI SEPI A O PAPER FURNISHED O PUNCH HOLES O REVERSE READING O 35MM MICROFILMING O XEROX PRINT ONE SIDE O STAPLE (S) O SILVER FILM O tosuu MICROFILMING Ol Firushed Size O PRINT BACK TO BACK O FOLD TO O WASHOFF FILM O 35MM APERTURE CARD C FOLD To O PAPER COLOR O TRIM TO O KP5 PAPER O 35MM oUPtiCATE I STAPLE (S) O SPECIAL PAPER O PAPER TRANSPARENCY O APERTURE CARD O PUNCH HOLES O COPY SIZE CLEAR FILM O, 16MM FILM l COLLATE O sw x 11 O ti x 17 O SCREENED IMAGE O PROCES$1NG ONLY O! PRINT AS PER SAMPLE O 1s/35Mu ol AZO DUPLICATE ROLL O 16MM CARTRIDGE LOAD ONLY O! 3M O KODAK O j i DESCRIPTION OF WORK ' iCopyright Material Cannot Be Reproduced Without Permission Of Copyright Holder) I
. ORIG. l NO. OF COPIES Il DRAWING NUMBER l DESCRIPTION OF ORIGINAL I $ 1 1 663273-4-2 I Fl_0W DIAGRAM - WESTINGHOUSE i '
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I l t i l SPECIAL INSTRUCTIONS RETURN ORIGINAL TO: NAME: RECORD FILES ROOM 2100 C ADDRESS: RETURN NEGATIVES C DELIVER TO: C. K. MAXFIELD PHONE WHEN READY [- EXT. 9OM: DEPARTMENT: DIVISION: MAIL WHEN READY [ ADDRESS: Diabl0 Canyon REO. NUMBER ENCLOSURE #2 ___ _ ___ =_ _ _ _______ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
4 i DIA3LO CANYON HAULING UN.T Vende'rH ' [ l Dwg6s-10SE-m STATOR GEN. TRAVEL AR.cEIGE: Err
, BIOGE CRAE RIGOING SPEC. 8823
, Rev Date Rec'd Quan Distribution
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-1 = APPROVED FOR CONSTRUCTION R.A.C.a RETURNED FOR ADDITIONf.L CORRECTIONS R.
- REQUESTED S.N.s SUBJECT TO NOTATION O. = ADDITIONAL COPY A. S.: APPROVED AS TO SUBSTANCE N.A. SNOT APPROVED R. S. = REVISED G RESUBMITTD: BY P. G. 8 E.
N O. COPl!! DATE DISTRIBUTION TO PGBE i VOID DESCRIPTION ISTRIM HON DRAWINGS REV DATE DATE COPIES OF T CHECKED COPIES N O. OF R E C ' D. R EC' D. PRINTS OUT DATE COPIES SPEC. OPIES RETAIN. FILE RACK OTHER REV. MADE app HM S. MMG. N O. mmy. ON APPROVAL FILE i i i . h C7 UNIT / GMI67027 CiUNIT 2 GM I69972 0, D/ABLO CA N. YO N SITE
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- D"!G. 10 0. 17 CONTRACT NO.
I'clAMUFACTUREa MURPHY PACIFIC CORP.
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; ! i ENCLOSURE 17 1 i- , , i ,
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>-hh._ .%_.e PACIFIC GAS AND ELECTRIC COMPANY I General Construction Date.. ...b.7.M..2....Y.[
To.....R,. S ...BAIN/J. W. WOODWARD ROOM 1465,
]
. 77.. BEALE.. ST.. ...... ...... . . . .. .. . .. c.u. .td.Zcla..Z. . 24.ZF 72-SAN FRANCISCO, CALIF.
. D.P.O. . .
. . . R.. .
Attention: ..N.....de.'d 4c/4g.. Spec. No. ..[E.M... .. l Copies Drowing No. Revision SF Cont. No.
- Spec.No. No.
..A........ A. . ... . . .'.. A. .. . .x. ... .'o . . 7. . . . . . ...A..
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.. NOTE:
Ad e PLEASE FORWARD TO m:;E"z" ;33"(g73-yge" E i 7 pDATE RECEIVED.
'd RECEIVED BY .
RETURN ORIGINAL OF THIS TRANSMITTAL DATED AND SIGNED to. 273'l2- ENCLOSURE #8
r- o-r. PActitC CA!: AND El.ECTRIC COMPANY
*,t*[v'. *l,., s FIE6 CORRECTIONS OF STATION DRAs JGS TRAtJSMITTAL g,h
~17 k
- 0: GENERAL OrrlCE. 77 I:EALE S.F., CALIF. ATTENT10fJ: O SUuSTATIONS D ATE:" ~b~7I DEPT. OF ELECTRIC OPEn. O HYDRO GENERATION GENERAL CCNSTRUCTION O STEAM GENERATION O O COMr.1UNICATIONS F H 0f.1: k [, /l QgQ{
DIVl310ff: ADDRESS: {QQ yQgy STAT 10rJ: WO/G!.1 DCheck if none. DRIEF DESCRIPTION OR WORK DONE
- 4 ~~{.]g{
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THE FOLLO?l LNG ORMailNGS ARE FORWARDED FOR CORRECTIOrJ: DRAWING NO. C ange TITLE ~ 8-62 et (' MEM d VA L . COLlECL - I f3 i ( ' l l l . ' i l Received Recewed in Receeved By Received By Tracing Approved New Pesnts Ordered l Dept. Of Engr. Proicca Engr. Des. Draf tmg BY BY BY BY SO U* BY DATE DATE DATE DATE DATE DATE A PPR. APPR. AFPR. APPR. ENGR. APPR. INSTRUCTIONS. Uoon completion of job; immediately send in sufficient corrected drawings so that all related drawings can be corrected. Complete Cascription and nameplate data of all equipnient enstalled must be encluded. Upon completeon and approval of all drawing correctiocs. new prints will be distritsuted by the Engineering Department. At this time, one copy of this form will be returned to the Deves on Superintendent involved. The
,f II wing station drawings may be af fected: S nete Lines. Elementary. Diagram of Connections, General /.arangements, Arrangement of Equipment. Bills / 3aterial. Conduit Schedule. Cercuit Schedule. Drawing List. Description of Operations. Communications Drawmos, Manufacturers Drawmgs.
s Emj more complete instructions see " Instructions to Field Personnel on Preparation of Drawing Markups Due to Field Changes" - Aviil:ble from the Design Draf ting Dep't, Ficct. G&T Unit, Geners! Office. REMOVE SET.FROM PAD DEFORE USING REMOVE YELLOW COPY AND SEND WHITE AND PINK COPIES WITH CARDON INTACT.
, WHi1E Col *Y WILL oE RETURNED WHEN NEW PRINTS ARE ORDERED.
i D AI LY LIST OF NEW AND R EVIS E D DR AWINGS GM- 169 972 DATE 19 _ GM-lC7027 9.*+ DR AWING A N D R AWINGS D R AWINGS D R AWING S D RAWINGS NO* G (FRIEDRICHS) (NELSON). (TRESLER)
* (WRIGH{}
(SPE'C") (SPECD (SPECD (S PEC. ) i i - ! 1 E \ .. . 1 - l - l 1-l' i
- 1. I HAVE NOTED THE ABOVE AND HAVE PASSED IT ON TO MY Ef!GINEERS AND INSPECTORS. ENCLOSURE #9
- 2. *THE ABOVE FROVIDED SPECS, APPLY TO THE REVISION f OTED ONLY.
- 3. "ACCORDING TO SPEC. 8 PRC il, DOES THIS REQUIRE A APPROVAL ST,'.MP 7 SIGNED:
RESIDENT ENGINEER
\s') DIADLO h
CANYON SITE V UNIT NO. GM-ON JOB DRAWING INSPECTION REPORT DATE OF AUDIT CONTRACTOR SPECIFICATION P.G.8 E. DRAWINGS CONTRACTOR DRAWINGS ON RK. O-ON CONTROL SHTS.O ON FLD. RK. O-ON OFF. RK. O-OFF. REC. O DRAWitG DESCRIPTION c,o, fyn'v abIof co ev ab E f D NU BER REMARKS REMARKS NUMBER 81 ch acy ho Bloc" nev ho E r"- . 8 y COMMENTS: (Explain any discrepancy cnd corrective action taken) 2 , o NOTE: On Vendor dwgs. Only give the table of change rev.as well as the D.C. no. rev. ORIGINAL tor Of fice Engr. COPIES TO: Resident Engr.-Ouality Control 8 Contractor OF-t ("" 3-20-75) ' Sin NED:_ _
p ip O 76-2/.8' im' PAciric cAs AND ELECTRIC COMPANY l-7-70 = units 1 and 2 RECORD NUhtBER DWG. LIST - MANUFACTURERS DRAWINGS
'.s C3 Diablo Canyon an- 8700fM 00 EMM SPEC. 8700 #A800 SUPPLIER Westinchnuse ENCR. M 5*,"
r RECORD NO. bb321b - DESCRIPTION Safety Injection System SYSTEM N.S.S.S. r:LE NO. 140.090 Cw C 's. EQUIPutNT DATE AT T'D. S H.#REV STATUS D ATES QTY. M ANUFACTURER TITLE MrR. NO. R EV. DIST R. y RECEIVED /-9-73i20 ' Safety Injectinn System Description 46 2 d- RrTuRnfo Westinghouse SD-PGE/ PEG-200D / 3-I-73 g RECElvED //-/1 70 23 Minirm1m Flow Orifice Assembly 47 / C.- TETuRnED j-7 i, s Pacir.tc Pump B - 19049 5 /- 9-7/ ., RECEIVED 2-7-72. 2.Y S Conduit box Qutline for Safety In-48 / b RETURNED le. Westinghouse ' jection hunos
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/ ! R EC EIVE D W - 3 'l- 7/ / Ash 8 May. Data Renort for SIS I O i 51 RETuRurD' Delta Southern Acumulator tr.nk NB 26@ Unit 2 41058-70-2 -
S 4 'u 4 REC ElvE D 9- 21P // j ASIS I:fe Data Report for SIS l 52 l 6 9ETuRnED "~ Acumulator ' lank HB 2689 Unit 2 41059-70-1 - 4 - 6 '7/
' RECElvED // -21 7, f ASFS Mfg. Data Report for SIS 53 I O' RETuRNEn ." Acurmilator Tank NB 2690 linit 2 41059-70-2 6-b%
RECEIVED . 'A-2t 7, J enort for SIS 54 I b RETURNED
" ASl1R Mfe. Dntn,R Acunulator Tank Inl 2687 Unit 2 41058-70-1 -
S- 8 W e RECEIVED N /7 71 27
/ b Joron Iniection Flushinc Orifice e
55 TETuRnEn S n, Westinghouse 271G150 b' U@
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! 58 I C RETNRnED Stntthers Wells Inj o:: tion Tanks' Unit 2 Nat81 Bd. 13345 * *
* ,, e EEC EIVED G-7'll/ , Start-Up Test Procedure for Safety 59 1 C.- RETunnED Westinghouse Inicction systen 5.6.1 INL-M ,
R ECEIVE D ID-31-N R'n S,fety Iniection Systen Flou Diprne Sh 1 of 4 60 % b IETuRnED " Unit 2 1138E27 STATUS OR AWINC DISTRIBUTION AND ACTION " f A - PRELIMIN ARY af.T N E - APPROYAL ~ i R.BAIN/ MANNING 10cck1353 ACT. H O.
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PACIFIC GAS & El.ECTRIC CO. 3
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I APPROVED FOR C0HSTRUCT10tl r 3 c) D-
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ENGINEERING DEPARTf.1ENT BYIT/NinhDATE 6-d I9
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1 RECORD OF SKETCHES CHANGING ORIGINAL DES /3N DWG.'S I (
- SKETCH NUMBER ASStGNED ON SITE)
' D/ABLO CANYON UN/TS-/B2
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DRAWING NO.
$ W COPES TO DATE N O.
R CD j SPEC. TITLE CONTRAC CR
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D E E N T R A U 3.O ( D T E R O ) T E R D U E T N A G N I G
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BID LITHO AND ADDENDUM DISTRIBUTION RECORD SPEC. N2 AD D EtJ D UliS ATTAcilED DATE COPY 3 p7j 7, f , 7 ;, / /
/ DATE ASSIGNED TO DATE jp/./ / ,
LITHO <Y ,.l / , / l / l /, , flul'i3ER RECEIVED <-- L I I 1- e- 'A
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DI ABLO CANYON ' GM. STATI O N CONSTRUCTION REQUES T FOR A DDI TIONAL. DRA WINGS 1 DATE S P EC. N o. PLEASE TRANSMIT THE FO LLOWI N G... . PG $ E DRW.O MANUALS O VENDOR DRW.O OTHER. O TO t c l e l DISTRIBUTION
, O THIS TIME ONLY S/6 NATURE i O CONTINU ALLY OE.53 DATE 9-7-7!
OE-53 (9-7-71) ENCLOSURE #18
DIABLO CA!!YGIT PROJECT DIABLOCANYO!hPROJECT DRAWING PITUFJi TORM DRAUING RETURN FORM DATE DATE
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t 1: TO: w/
.hn following drawings you checked out are - The following drawings you checked out are VOID. .
VOID. Return immediately with this notice. Raturn immediately with this notice. PRINT ROOM PRINT ROOM Signed: Signed: OE-24 (Rev. 7-8-75) - CE-24(Rev. 7-8-75) DIABLO CANYON PROJECT DIABLO CANYON PROJECT DRAWING NM TOM DRAWING RETURN FORM DATE DATE 0-TO: The following drawings you checked out are y 7D* VOID. Ibturn immediately with this notice. Return immediate,1y with this notico. N NT ROOM PRINT ROOM Signed: Signed: OE-24 (REV. 7-8-75) OE-24 (Rev. 7-8-75) l DIABLO CANYON PROJECT DIABLO CANYON PROJECT l DRAWING RETUPJi FORM DRAWING PITUPli TOPJ4 l DATE , DATE TO: . TO: Tha following drawings you checked out are The following drawings you checked out are l VOI D. VOID. l l OR2 turn immediately with this notice. .-Return irmediately with this notice. PRINT ROOM PRINT ROO" l Signed: - Signed: l OE-24 (Rev. 7-8-75) OE-24 (Rev. 7-8-75) ENCLOSURE #19
CllECK IF: I
, Call constitutes a Drauing Change / ,
PACIFIC GAS AND ELECTRIC COMPANY Copy is to be returned O) D STATION CONSTRUCTION DEPARTitENT Diablo Canyon Project to Engr'g. Dept. for INCOMING / / their information / , SAN FRANCISCO TELEPilCNE CALLS Call requires a OLTTGOING / / Cont.rhetor DVR / , PERSON CALLED: DATE CALLED: TIME:
SUBJECT:
DRAWING NO. CHG: SPEC. N0% : _ _ 4R NO. :
'REASCN FOR CALL:
l i i 4 i DATE OF REPLY: TIME: REPLY RECEIVED: _ } s 4 ) , .. 1 NOTE: (1) FOLLON TilRU ON EACll CALL, VENDOR PROBLEMS, ENGILEERING CliANGES, ETC. 1:EEP CLOSE Cl!ECK FOR TIME LAPSE BETIGEN DATE CALLED AND ANSKER TO CALL OR PROBLE:' (2) IF Tills CONVERSATION CONSTITtTTES A DrlC. Cll'dCE, Tile RESPECTIVE CONTRACTOR A'
. . DESIGN ENGINEER WILL RECEIVF A C01'Y.
t cc:Res. Engr. SIGNED: , Fld. Engr. ENCLOSURE #20 File Startup I I Civil l l Mcch f 7 Elect; i Misc [ n? ( c.., 11/17/741
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,q PACIFIC GAS Afl0 ELECTRIC COMPANY U STATION CONSTRUCTIO:1 DEPARTMENT DIABLO CANYOU PROJECT
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,'.j .,.,,' ' .4 January 23, 1979
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. . mo T0: HOLDERS OF " PACIFIC GAS Ah(D ELECTRIC I COMPANY DIABLO CANYO3 PROJECT DRAWING CONTROL PROCEDURE" Drawing - liaintenance Procedure GCR-g is now the official procedure for maintaining centrol of drawings. Instructions for the operation of drawing cuatrol (OEI-1) has been issced to supersede Diablo Canyon drawing control procedure and provides instructions to drawing control personnel for issuing and maintaining control of all drawings received and issued through drawing control.
The copy of Diablo Canyon Project Drawing Control Procedure, in your possession, should either be marked " void" or " superseded", if retention is desired. If retent. ion i's not desired, then dispose of the procedure. If you desire to maintcin OEI-l current or do not desire to retain it, check the appropriate box below, date, sign and return. p ! h,4 Q ILM:nj I .L.1%CD0liALD
Attachment:
Instructions for the operation of Drawing Control. Detach and Sign T0: I.L. MACD0fiALD
SUBJECT:
INSTRUCTIONS FOR TliE OPERATION OF DTJMING CONTROL (CEI-1)
) I do not desire to remain on the distribution list.
O I do desire to remain on ene distrisution iist. (Signatura) (Date)
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PACIFIC CAS AND ELECTRIC COMPAtlY STATION CONSTRUCTION DEPARTI'ENT [ DIABLO-CANY0tl PROJECT OFFICE ENGIIEERING PROCEDURE NO. OEI-l .. TITLE: Instructions For The Operation of Drawing Control Procedure OEI-l APPROVED: -( .hh DATE: /-le-7.9 Revision 0 A Page 1 of 14 1.0 SCOPE This procedure establishes the responsibilities and requirements for receiving, issuing and maintaining control records for all company, contractor and vendor drawings, manuals and Specifications processed through Drawing Control. 2.0 RESPONSICILITY 2.1 The Supervisor of Engineering Services is responsible for inplementation of this instruction. 2.2 The group leader of Document Control is responsible for the training of assigned Personnel, conducting drawing audits, Issuing drawings, manuals and specifications and the maintenance of proper records. 3.0 APPLICATICU 3.1 This procedure applies to all controlle'd and approved drawings used at Diablo Canyon site, aad complies uith Drawing Maintenance Procedure GCR-9. 3.2 Drawing Control itecords 3.2.1 Comnany Drawing Control Sheets (Enclosure al) These control sheets will be maintained for each company . drawing received at the site. On this sheet is indicated the current information concerning dates, OFTICE ENGINEERIt!G PROCEDURE ?!0. OEI-l quantities, distribution and filing information, or all revisions pertaining to that drawing. The appropriate rack number or numbers for the drawing will be indicated in. the lower right hand corner of that sheet. An asterisi; and stamp
' stating approved for construction along with color highlighting will be used to indicate Approved for Construction drawings.
3.2.2 Vendor Drawina control Sheets (Enclosure #2) A sheet 'will be maintained for each vendor drawing received at the site in the same manner as the Company Drawing Control Sheets, except that only an asterisk will be used to indicate approved for construction. 3.2.3 Vendors Drawing Control Sheet for Contractor Field Drawinos, etc. (See Enclosure #3) This fom serves the same' function as the company drawing control sheet except that it is used for various contractor drawings and proceduras. Ths form provides for following the individual drawings and procedures through their approval stage as well as distributuion. 3.2.4 Vendor Rolodex Card or Control Sheet Files for Drawinns without Pecord Numbers (See Enclosure #4) - A card or control sheet will also be maintained for each vendor drawing that is T l not assigned a record number. Each drawing will be recorded by. vendor drawing numbers, specification, structure or area and as a last resort by vendor name. All of these drawings are filed in a miscellaneous file by specification. 3.2.5 Vendors Drawino and Insnection !?anuals Record (Cnclosure #5) On this fom is maintained all the infomatio'n pertaining to vendors drawing and instruction raanuals with cross references to the various identification numbers. The key feature of this fom is that it will be filed by type of equipment rather than numerical sequences. This provides a system that allows an engineer or inspector to locate drawings and/or manuals ly type of, equipment without requiring knowledge of either record or drawings number. 0FFICE EftCil:EERIt!G PROCEDURE NO. OEI-1 M
] 3.2.6 Transmittal forms 77G4 9/78 (Enclosure #6) and 62-5537 (Enclosure #Ga)
Form 77C4 9/70 will be used for transmitting all drawings, except "as-builts" to Engineering. Form 62-5537 will be used to transmit "as-builts" to Engineering. 3.2.7 Daily List of New and revised Drawinns (Enclosure .87)
- Each day the print room personnel will publish a listing of all company and vendor drawings received that day. This listing will also include sketches, and DCR's that constitute a drawing change.
These company drawings received with a notation, " Approved for Construction,"
" Issued for Fabrication and Installation", " Approved for Planning and ffaterial Procurement, "etc. will be noted with an asterisk on the listing.
3.2.8 Receival of Drawines All incoming drawings, specifications and manuals are to be delivered to the printi room directly before any distribution is made. One copy of all sepias without p prints received will be shown to respective departments to see if it is urgent.
~U If urgent it will be reproduced imediately and placed on the inspection table, othensise it will be set aside to avait normal distribution from San Francisco.
At the same time the balance of the drawings with sepias are being spread out on the layout tabl~e, sorted, counted and the date stamp placed on each one. Drawings received from vendors and contractors will arrive with several copies of an engineering department transmittal attached (See Enclosure #8 for sample). This i transmittal will have the vendor's name, purchase order number, record number, sheet , number, and. description on it., , l 3.3 Distribution and Filinn
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! 3.3.1 Information will be provided by the Resident Engineer regarding the number l l of copies of company drawings to be provided each contractor. Company drawings which i
- , - - - - - - -+ , - - ._ _ m .-- .- -- _ , _ - - - . - - - _-,
OFFICE Ef!GIllEERIllG PROCEDURE N0. OEI-l m are identified to be withheld from the contractor will not he distributed and a note (V s to that effect uill be transmitted to contractors on the job site when requested by the responsible Resident Engineer. . A letter of transmittal (Form 77G4 9/78, Enclosure #6) w'ill be made up for all drawings transmitted to contractors at their job site headquarters. An original and two copies of the transmittal are prepared, and third copy retained cn filethich serves as a basis for determining what transmittals have not been signed and returned. The third copy is destroyed when the signed transmittal is returned. The same system will be used for form 62-5537 (Enclosure #6A'). p 3.3.2 At the beginning of each week the Active File is to be checked for outstanding transmittals that are unsigned for more than a week. A xerox copy of these transmittals will be sent to the o'riginal addressee with a statement as follows: According to our records we have not received a signed copy of this form, due to loss or mix-up en route. Verification of receival is necessary to complete our records. Please check your files and return O this signed. Thank you for your cooperation. V 3.3.3 Ilhen drawings are received, the following steps are taken: A. They are date stamped. B. They are separated into four categories: Contractor, Rack, File a'nd table copies. C. All are recorded en the control sheets. D. One copy of each will be placed on the racks provided for each e
- category.
All superseded drawings will be removed from filing cabinets and racks and de-stroyed, except the reproducible, which will be marked VOID - FOR REFERE!!CE ONLY
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and filed separately for possible future reference. In the event no reproducible n n - , ,- .,, , ---m ---n--, . , , ---n - - - m
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t-OFFICE Ef!GINEERI:1G PROCEDORE N0. OEI-l is on file, a print will be kept. When all superseded drawings are removed from files and racks, the remaining new copies can be folded, marked with number and revision on the top right hand corner and filed. 3.3.4 For drawings received from vendors and contractors, a divider with the drawing number will be inserted between each new drawing in the file. All of these dcawings will be filed behind the identifying divider. Void drawings will be processed as'with company drawings. A print also will be retained for future I reference if there is no reproducible available for that purpose. ~
-X 3.3.5 One copy of each approved drawing received eaph day will be placed on the l provided inspection table for the information of company engineers and inspectors.
All new drawings, drawing revisions, sketches, as-builts and DCR's received each day wiil be listed on the DAILY LIST OF NEW AND REVISED DRAWINGS, which will be provided to each Resident Engineer, indicating what, drawings have been received pertaining to their respective areas. After 48 hours, clock time, the I i drawings will be removed from the inspection table and placed in the file.
^
3.3.6 All drawings taken from the files will be signed for by the individual requesting the drawings. This accounting record will be maintained on the out card filed with the drawings. It is the responsibility of the individual siS aing
- for the drawing to return same when requested or when he no longer has a use for I
the drawing. l 3.3.7 Drawings issued as " sets" (i.e. piping schenatics, instrument schematics, i electrical schematics and arrangements in 11", X 17" and 81/2" X 11' size), will be signed out as a set, and will be returned copplete. (a) Distribution of the revision ! will be made automatically to all P G and E personnel on record. (b) The processing of superseded drawings in these " sets" will be the responsibility of the respective resident engineer. , O .
.m . . - , ___ -. _ - _ _ _ _ __
0FTICE EfiGIflEERIflG PROCEDURE tiO. OEI-l Superseded Drawing Processing W 3 3.4 i j 3.4.1 In paragraph 3.3.3 it was stated that superseded drawings, will he withdrawn from the files and destroyed, except for one reproducible marked VOID - FOR REFEREilCE Oi!LY and retained for possible future reference. Any drawings that have field notes marked on them will be taken to the respective engineer / inspector to see if an - i "as-built" drawing is required, or whether the notes are worth saving. If the notes are to be kept, the drawings will be stamped and handled as above. 3.4.2 Uhen superseded drawings are removed from the file, the outcard will be checked *
- to determine those individuals who are signed out with the superseded drawing. Drawing return foms (E0-24), Enclosure #9, listing applicable drawings will be issued to the appropriate supervisor for action by the person named. (A duplicate copy will be kept on a suspense file in drawing control). .
4 The signed OE-24, indicating the action taken, must be returned to Drawing Control within 7 days of its issue date.
- 3.4.3 Upon receipt of the returned OE-24, drawing control personn'l e will take action
- a's follows:
j 3.4.3.1 .When drawings and the signed OE-24 are returned and the individual does not desire to retain the void drawings: Drawing control personnel will delete the l individuals name from the drawing "out card", correct the drawing control records and i i dispose of the void drauings, the suspense and signed OE-24. 3.4.3.2 When drawings and the signed OE-24 are returned, and the individual desires to retain the void drawings: Drawing contro) personnel will stamp 'the drawings VOID - FOR REFEREtlCE 0*iLY, indicate on the drawing "out card" that it has been retained by the individual, return the stamped drawing to the individual dispose of the suspense and signed CE-24. 3.4.3.3 When the signed OE-24 is returned, indicating that the drawings are not available for return: Drawing Control Personnel will indicate on the drawing "out card" and the drawing control records, the reasons for their non-return, dispose of the [
i l l OFFICE EtlGIllEERIt:G PROCEDURC 110. OEI-l - suspense and signed OE-24, 3.4'.3.4 The drawing control OE-24 suspense file will be checked daily and-notifications sent to the supervisors of those individuals who'are deliquent. 3.5 Drawing Audits 3.5.1 Drawing audits of all contractors, whose contract requires quality assurance,
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will be condJcted weekly to verify that their drawings are current. A minimum of ten drawings for each contractor will be compared to the drawing contro,1 records (unless a contractor has less than 10 drawings then all drawings will be reviewed). The person conducting the audit will: 3.5.1.1 List the drawings which are reviewed by drawing and revision number on Form OE-1, (Enclosure #10) "On Job Drawing Inspection Report". The latest revision on the P G and E drawing control sheets shall also be listed.
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3.5.1.2 Any discrepancies shall be noted in the comment section of the report. 3.5.1.3 Drawing audits shall be submitted to the appropriate Resident Engineer for any corrective action necessary and subsequent distribution to the contractor and Quality Control. 3.5.2 Drawings maintained in the field by P G and E DRT, Instrumentation and Startup groups shall be compared to the drawing control sheets to verify that the drawings are current. A minimum of 10 drawings for each group, shall be reviewed each week. The person conducting the audit will: . 3.5.2.1 Same as paragraph 3.5.1.1 above except a Form OE-79 (Enclosure #11) will
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be used. 3.5.2.2 Same as paragraph 3.5.1.2kbove. 3.5.2.3
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Drawing audits shall be submitted to the appropriate Resident Engineer for review and corrective action if applicable. '
OFFICE ENGINEERING PROCEDURE NO. OEI-l 3.6 Processinn of Sketches and/or Partial Channes y Ir order to expedite necessary design changes, or to ma.ke.sm,all changes in .
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dIahi6gs, B'l/2" X 1f" "R'e'visfoh"Shbets "(sketdhe's will'beEhkli,ze *(SeeEnclosuYe
#12 for sample). These sheets may be transmitted by company mail or, where expediency dictates, by telephone telecopier. DIABLO CANYON SKETCH # h 5HT. OF .-
- Sal No. A55fGNED ON SIM 3.6.1 Receival and Distribution (Figure 1) llhen a sketch, which constitues a drawing change, is received the Diablo Canyon sketch stamp (Fig.1) is applied. Before distribution is made. Then a sketch number (indicating sequential sketch issuance) are assigned. Sketch numbers are logged on fom OE-2, Record of Sketches Changing Original Design' Drawings, (Enclosure #13),
then distribution is made. Sketches will b'e distributed to all contractors who.are recorded as having copies of the drawing being affected by the change sketch, unless directed otherwise by t!m responsible Resident Engineer or his delegate. sy 3.6.2 As-Builts The changes to drawings or sketches showing "as-built" changes to be made to l other drawings will be initiated by the Engineer or Inspector in charge of the individual structures or systems. They are responsible for making up the print
- with the proper color pencils, (green for deletions, red for additions), giving I
all dimensions. and sufficient information to, adequately show the actual "as-built" condition of the structure, system, equipment, ,etc.."As-built" sketches are confined to 8 1/2" X 11" size xerox copics whenever possible. t! hen the Engineer or Inspector completes an "as-built" drawing, he will stamp the sketch or drawing in red ink and fill out the blanks per the sample shown below, (Fig. 2), before turning it into the print roon for distribution. FIGURE NO. 2 g g q]Pg Q yy[j M (((( DWG No. 69 N'I
-a F.:CN/M.G-p.4DATE 1-I-E
i 0FFICE Ef!GINEERIttC PROCEDURC NO. OEI-l . He will also indicate unit involved and brief description of change. The ! print room will assign a sketch number (as d,escribed .in' paragraph 3.6.1) and' - - reproduce the number of copies required for distribution. The* city. copy will
' l be given to the draftsman to be marked up in the same manner as the original.
When the draftsman completes the changes to the copies, he returns them to i i the print room for distribution. , 1 Distribu' tion of "as-built" sketches are made to engineering, originator and
- original to print room file, unless directed differently by the Resident Engineer or his delegate.
j In the case of extensive changes, where full sizdd. drawings are marked up, only the original and one copy will be made. The original will be retained in the print room and the copy will be sent to the Engineering Department for incorpora-tion on the next revision. 3.6.3 Approval of Drawing Changes
- Approval of drawing changes will be in accordance with GCR-9.
- , When information is received that sketches are incorporated en newly revised
. drawings, the copy from the unincorporated files will be removed and maintained j for a short period in the dead files. The sketch incorporation date will be i entered on the OE-2 form, Enclosure #13 (Formerly Form ES-2) i 3.7 Process of Specifications, Lithographic Sets and Addendums All specificat' ions received will be accounted for on the specification and
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, OFFICE ENGIflEERIflG PROCEDURE fl0. OEI-l revision Distribution Record (Enclosure #14). A specification wil.1 be filed in the Specification Correspondence file or assigned to an individual by initial. When revisions are received they are issued to the appropriate holders. ' Specification
! Change Orders will be processed using the fom shown in Enclosure #15. Lithographic , sets and addendums thereto will be processed as above using the.fom shown in Enclosure #16. . 3.8 Aperature Card Listing . 1 This listing is provided on a biweekly and monthly basis by City Records Depart-l ment. Upon receipt, the biweekly listing will be checked by the print room personnel to verify that we have received all the drawings and latest revisions listed. If there are any deviations noted, an appropriately marked xerox copy will be returned
- to City Records Department for their action.
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O 3.9 Information Only Drawino These drawings, either Vendor or Company, are sent to the contractor upon request from the Resident Engineer or one of his delegates by use of Form OE-53 (Enclos-ure #17). "They are sent to the contractors for their information only. If the j drawing is requested on a one-time basis only, it will be stamped FOR INFOPRATIO!! OflLY: however, if contractor is on a regular distribution, the drawings will not be stamped. Subsequent changes to IflFO O!!LY drawings will not be sent to the l contractor un'less requested. All drawings i the contractor's possession aarked FOR INFORf1ATI0f! OI LY will not be subjected to audit by Company Personnel, since these drawings so marked are' not to be used for construction. In the case of Spec. 8802, i i Drawings that are issued for a specific job on a "one time only basis, will be marked "To De returned to P G and E upon completion of work" instead of information only.
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OFFICE EllGIllEERIllG PROCEDURE fig. OEI-l (3 d 3.10 !festinnhouse Engineerina Change flotice (ECf!) Upon submittal of an ECM for approval, the original will be sent to Engineering , Departmeric for approval. When the ECN return's approved, it will be given to the respective Resident Engineer to read and sign. He will then return it to the print room for distribution. 3.11 Design Change Recuests (DCR's)
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GCR-12 establishes the responsibilities and requirements for implementing the use of DCR's. Drawing control is responsible for processing and control of DCR's. This will be accomplished as follows: 3.11.1 An on-site DCR log sheet (Enclosure #18) will be.used to identify and control them, the same numbering system employed by engineering is established, except the letter following the unit identification will be "G" instead of "E". This numbering system has been established by the fluclear Project Engineer's office and consiist of the following:
. Diablo Canyon Unit 1 DCl-{-(-D01 Diablo Canyon Unit 2 DC2-G-E-002 e
Diablo Canyon Unit 182 DCO-G-li-0 General Construction Civil Discipline-I
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Electrical Disciplinc' I itechanical Discipline . Sequential f! umber From Site 3.11.2 Upon receipt of the DCR Drawing Control will check to insure that it has been signed by the appropriate Resident Engineer and it has the l
0FFICE ENGINEERING PRDCEDURE NO. OEI-1 1 necessary information. The next sequential number, with the appropriate discipline, util then be assigned and recorded on the log sheet (Enclosure l !19) and the DCR. The required ~ copies will then be made and distributed and appropriate entries made in the log. A DCR initiated by Engineering will be logged on Enclosure fl9, and appropriate distribution made. 3.11.3 When the approved copy is returned to the site, the appl,.icable log entry will be made and appropriate distrubotion made. 3.12 Design Change Motices (DCN's) When a DCR has been reviewed, coordinated and signed, by the appropriate engineering discipline, it becomes a DCN. When a DCH is received the appropriate entries will be made in the applicable log sheets (Enclosure #16 or #17) and distribution made.
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OFFICE EllGIf!EERIf!G PROCEDURE NO. OEI-1 1 O 4.0 ATTACHf!EllTS ErlCLOSURE flut* DER - - 1 COMPAftY DRAUING CONTROL SHEET (DE-7) j 2 VEf! DORS DRAWING CONTROL SHEET (OE-8) 3 CONTRACTOR FIELD DRAWINGS AND PROCEDURES (OE-55) 4 VENDOP, ROLODEX CAP.D FILES S VENDORS DPAlliflGS AND IfiSTRUCTI0fl !!AfiUALS RECORD (OE-29) 6 TRN15!1ITTAL FORM (77G4 9/78) 6a TPAf!SMITTAL F0PJ1 (62-5537) 7, DAILY LIST OF flew AND REVISED DPAUIf GS (OE-6) 8 ENGIf;EERIriG DEPART".EtiT TPAtlSMITTAL 9 DRAWIfiG RETUPJi FORM (0E-24)
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l 10 Oft JOB DRAUING IllSPECTION REPORT (OE-1)
, 11 ON JOB DRAHIflG INSPECTION REPORT (OE-79) 12 SrsETCH REVISIO!! SHEET 13 RECORD OF SKETCHES CHA!!GING ORIGINAL DESIGN DPAHIt!GS (0E-2)
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14 SPEC. A!!D ADDEliDUf1 DISTRIBUTI0ft RECORD (OE-ll) 15 SPEC.CHANGEORDERDISTRIBUTI0ft(0E-12) 16 BID LITH 0 AND ADDENDUM DISTRIDUTI0ft RECORD (DE-13) 17 REQUEST FOR ADDITIONAL DRAUIf;GS (0E-53) 18 DCP, LOG SHEET l 4 19 CITY DCN LOG SHEET
5.0 REFERENCES
5.1 Drawing f:!aintenance Procedure GCC-9 5.2 On-Site Drawing Control GCP-12 i
. - . _ - . . . _ . -- . . =_ . . . . ..-_ .
l i 0FFICE EtlGIfiEERIftG PROCEDURE NO. OEI-1 O 6.0 CAriCELLATI0ff i j 6.1 PACIFIC GAS AND ELECTRIC COMPANY Diablo Canyon Project Drawing Control i i Procedure. I i i i O
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l M MICRU/lLM R. REQUESTED - E. EXPEDITED COPY O ADDITIONAL COPY OF EARLIER CHANGE REQUESTED A. ADVA NCE V APPROVED FOR CONSTRUCTION R PRELIMINARY ggAy/gg Ng, A ISSUED FOR BID N.O.S. NOT ON SITE pw...-....--,,_...- . _ _ __ T__
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0' UNIT / GMIG702Y 0 UNIT 2 GM /69972 D/ABLQ C.QNYON SITE' TITLE: ORAWING NO. RACK NO. Company Drow' g Control Sheet er:ctosune at
O N A. NOT APP'O 8 REVISED A.O.S APP'D ON SITE O 4e APP'D FOR CONSTRUCTION O A.S. APP'D AS TO SUBSTANCE C.F.C COPY FROM CONTRACTOR A AGREES WITH CONTRACTOR COPY
' S.N. SUOJECT TO NOTATION P. PRELIMINARY O. ADDITIONAL COPY R. REQUESTED Co. Von. Number Dis rihuIton To R G.a E. Distrbutiwi "v0/D " Drawings Ven. og, o ,g,.
Date Copics of' Rev Rev. Rov. Date Copios Copies Copies Roc'd Roc'd Prints Spcc.Na File Rock E/old Rot:in:d N2 N2 Date falado Trans. Trans. Destroyod1 on Fala 1 i i I l . DIABLO CANYON SITE - D UNIT I GM 167027 0 UNIT 2 GM IG9972 RECORD N O. TITLE: JOB NO. DWG. NO. CONTRACT NO. MANUFACTURER mwsuas #2 v ~ t, - ru. . . . . ., , ., p ,.,1 n n csni o w.y un
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O O O O s APPRCVED FOR CONSTRUCTION R.A.C.s RETURNED FOR ADDITIONAL CORRECTIONS R.sREdUESTED S.N.s SUBJECT TO NOTATION O. s ADDITIONAL COPY A.S.s APPROVED AS TO SUBSTANCE I N.A. SNOT APPROVED R. S. = REVISED 8 RESUBMITTED BY P.G. 8 E. N O. COME DATE DISTRIBUTION TO PGSE VOID DESCRIPTIO'N E N GR. CONTRACTOR DIS T RIBUTI O N DRAWINGS R EV. DATE DATE COPIES OF~ T CHECKED CCFIES OF PRINTS OUT DATE COPIES ' SPEC. ONES RETAIN N O. R E C' D. REC'D. FILE RACH OTHER FOR TRANS. TRANS. N O. DESTR3y ON REV. MADE APPL, APPROVAL . FILE . l i
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l DUNIT/ GM/67027 CUNIT 2 GM I69972 i D/ABLO CA N YON S/TE CONTRACTOR FIELD DR. AIVINGS & PROCEDURES ENCLOStlRE R3
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i DIA3LO CA:ir0:1 HAULI!;G UN.T * *
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U) PACIFIC GAS armi ELECTnlC COMPANY / / General Construction Date .... fb$:bbTf.2 _. . . , 1s To ./.&/.m' .. sp <!/:/dt.k../.$
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Attention: . . . . _ . . . . . . . Contraet No... .. Copies Drawing Or Revision - Description ~ Spec No. No.
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nETunN Oa:CII:t.t. OF Tlil's TII A!;S.'.*ITT/.1. DATED AND SIGNCD to.. '8
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mi.e: PACirlC CA*: AND El.tCTntC COMf'ANY g
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. .s: CENCHAL OFFICC. 77 DEALE 5.F. CALIF. ATTEi; TION: O SUtlSTATIONS DATE: Y/'7Y
. OEPT. OF ELECTntC OPEn. O HYDHO CENERATIOtt GENERAL CONSTRUCTION O STEAM GENERATION O COMMUNICATIONS s
FROM: k, J.[, j {M Q (~',, DIVIS10ft: ADDRESS: Q{Q pp-[ STATION: WD/C'.1 Otheek if none. BRIEF DESCRIPTION On WORK DONE g4 [h }3]g[g -
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THE FOLLO?l LNG CRA'.*!!NGS ARE FORWARDED FOR CORRECTION: Chang
- DRAWING NO. n,_ TITLE 8 'J5 F c1 o MIMA O 'VA L . COdTc'CL -
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Heceived Received in Received Dy Rece.ved By Tracing Approved New Prmts Ors:cred Dept. Of Erty. Prosect Engr. Des. Oraf ting BY BY BY BY SOD. gy DATE DATE DATE DATE DATE DATE A PPR. APPR. APPR. APPR. ENCR APPR. INSTRUCTIONS: Upon connpletion of job? immediately sand in sufficient correctort drawings so that all related drawings can tro corrected. Comptato e%ce sitio.i and nameptate stata of all egoipasent installed must be incluetod. Upon completion and approval of aff drawm) correctinc.s. new prints wilt t p'estratented by the Engineereng Department. At thes teme, one copy of thes form will be returned to the Oswision Supermienevent mvolved. The
)2ing stat.nn strawings may lie ef fectal: S.ngle Lines. Elementary Du'2 rem of Connections. General Arran0ements. Arrancement of [4mpment. Bil:s wtatissal. Conduit Schatute. C.rcuit S h. dure. Dr .ng List. Description el Operations. Commun cat *ons Draw.ngs. Atanufacturers Uraw'ngs.
Fcr rnore complete instructiont see instructions to Fic!d Personnel on Preparation of Drawing Markups Due to Ficid Changes" - Availit;!c from trio Design Draf ting Dep't. Ilect. GLT Unit. General Office. , RCMOVE SET FftOM PAO Ot ront U*.ING
. ENCICSUrs #6a IREMOVC Yt.'.LCW COPY AND SEHO WeetTr. ANfs PINK CrirlCS WITH CANNON INTACT.
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D AILY LIST OF NEW AND REVISED DR AWINGS GM- 169972
, DATE 19 _. ,
. GM-lG7027
^ h civil ELECTRICAL MECHANICAL START-UP
^ D R AWING'S DRAWINGS D R AWINGS N DRAWINGS N O.
c (SPE'C") (SPECb (SPECD (SPECb
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- l. I HAVE flOTED THE ABOVE AND HAVE PASSED IT bN TO MY ENGillEERS AND INSPECTOR S.
- 2. *THE ACOVE PROVIDED SPECS. N' PLY TO THE REVISION fl0TED ONLY.
Ef:CLOSU".E#7
- 3. "'TACCORDING TO SPEC. O PRC II, DOES THIS RECUiRC A APPROVAL STAMP 7 SIGNED:
[LTCh%@iC W FGWKWJM
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75-248' *m' PAcinc CAS AND ELECTRIC COMPANY 1-7-70 = Units 1 and 2 RECORD NUhtBER DWG. LIST - MANUFACTURERS DRAWINGS
'J O S Dlihlo Canyen 4R- R700tqP00 Euu SPEC. 8700 /A800 SUPP' LIEN Vestinrhouse ENCR. im 3*e w RECORD NO.bb3216 - DESCRIPTION Safety Injection System SYSTEM II*O *0 *0
- c' LLC NO. 140.090 DWC
- 3. EQUIPUENT DATE i AT T ' D. S H.#REV STATUS D AT ES Q T Y. MANUFACTURER TITLE WrR. HO. REV DisT n.
9c d REC E tVED /-(/-T4 WO Sarnty TniccH nn Svat,em Deneription 46 2- nr runeg o Westint;houso ' SD-10E/ PEG-200D / 3 - I -D
+ 9tcEivro //.e-1 'M U Minf rmim Plov Orlfico Annembly
47 / C.- utvanco i v i, s Pacific Puitp B - 19049 5 /- 9-77 . .
RECEIVE o 2-7-7 2. M
- C Sn'luit IloX Qutlino for Unrety In-4R / ntrunnro I ,. tiestinghoune ]ection hunna
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C71-TST / 4-13-72. 's,. Nf(_ ArctiVEo $ Q *[f'TQ) J.,I .S .' l.nu llen<l Inj ection Petth Sheet 3 of 4 - lh b 8
'7 ts 4 RETUithEo ,,, j , ,*. _ # En[lneering' P]ngs (lins'rsom linit 1 110 9 32 Ig /$ #/~7j DECEIVrT. . *
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t. I 0-ntersvro 4-21-7/ / . ash 8 'etre. Dutn Itenort for SIS I 51 RtTennro Delta Southern Acuou intor ir.nk IIB 2M8 UIilt 2 41058-70-2 - S % nrctivEn 9. n .-er i ~'1311Hfe. Data Report for S1S 52 I 6 nrrunnro "* Acuinulal.or 'Innk I;lf 2tiR9 Unit 2 41059-70-1 - f. - r,. 4/ ' nt crivt u 0-21-7, i ASME Hfg. Data Per. ort for 51S i 53 I d' arruntm, a
~Kcurmilator Tank NH 2(/30 lintt 2 41059-70-2
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$4 / b nEtuunto a ~Acurculntor Vnii,J_1e_Illi k 2687ngrt Unit for SIS2 41058.-70-1 '
S' A e 9 - / 7 74 55 /b nterivro ntronnro 2T _ Sp. Westinghou.se 3.oron Iniection_Elud110a orifice 2710150 f. W-7 2. .' ; 56 I d' . NE$.. . h k2f0n Nffk h b c " 0-678297 7*M'D ' 0 nEct. ..:t W-/A L i' Perindic Test Snfety In f ection 57 [ pcTu1nto
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58 C- FEWRNED Sintthers Vells Injection Tanks' Unit 2 Ust81 Rd. 13345 *
*U l r.Ec Eivr a 12711/' 'r ' Start-Un Tact Procedure for .ttfety l 59 1 C. arrunnro Westinghouse InjectiliR~Bys tern 5.6.1 INf 'M frf.31 lLI M S1fetV Iniection SYSTEM Fl ott DiFrnr R E C EiVF D 60 9 b ntTuRnto H Sh 1 of 4 Unit 2 E
11]8E27 . STATUS on AWING DISTRIBUTION ANo ACTION .. ,, ' p A - PREttutH ARY
?'"f N o. ACT. No.' " D C" ech I -
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27u~9 l$ prou AE0 ACTloN II.J. Germly 2G55 T J.W. CULM.LL E'11 t l$ ""-- = ~ Ot)1 2 4 t! ' * . *
- l A.G. WALTilER 2ec $93 T u ' p.P. J5))TJgg g ;E10 '
0- APPROVAL o- CouucN1-
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i, 1_I*Il* lIOC'CA 250)
.~7- 1.F. ELL -(cc DEALE STREET
- INronuATsoN
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(L-) DIABLO Can PROJECT (' ~') DRAWING RETURN FOR!4 Date (Issue Date) T0: Department Supervisor; (Civil), (Electrical), (Mechanical), (Startup.), (QC), (Cleanup Crew).
. FOR ACTION BY The following drawings you have checked out are VOID. ,
(a) (b) (c) . Drawings I desire Drawing Number & Returned to Retain Any Exceptions to Columns (a) & (b) (Note 3) Revision to Drawing Drawings Control (Note 2) , (Note 1) so . 5 y
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*E Notes. 1. Drawings and sigried OE-24 must be returned to Drawing Control within,7 days of the OE-24 issue date. .
- 2. Drawings, as well as the signed OE-24 must be returned to Drawing Control within 7 days of the OE-24 issue date. Drawing Control will affix the proper stamp to tne drawings, make applicable record entries and issue the drawing.
- 3. Any exceptions to Columns (a) & (b) must be explained in Column (c) and the signed OE-24 returned to Drawing Ccntrol within 7 days of its issue date. ,
OE-24 (1-l' 79) Signed
PACIFIC GAS AtlD ELECTRIC COMPAflY
-m STATION CO,'!STRtICTIO!! DEPARTi!EllT
) DIABLO cat 1Y0!l PROJECT 2
0FFICE ENGIflEERIllG PROCE' CURE NO. OEI-l TITLE: Instructions For The Coeration of Drawino Control Procedure OEI-l APPROVED: d$k((. DATE: 3 J'- # Revision 1 J Page 1 of 14 1.0 SCOPE k , ,
.s This proc.edure establishes the responsibilities and required:ents for receiving, issuing and maintaining control reccrds for all companb contractor and vendor
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drawings, manuals and Specifications processed through Drawing Control. 1 i p V 2.0 _RESPO!!SIBILITY l 2.1 The Supervisor of Engineering Services is responsible for implementation of this instruction. 2.2 The group leader of Document Control is responsible for the training of assigned Personnel, conducting drawing audits, Issuing drawings, manuals and specifications and the maintenance of proper records. 3.0 APPLICATION l 3.1 This procedure applies to all controlled and approved drawings used at Diablo Canyon site, and complies with Drawing flaintenance Procedure GCR-9. 3.2 Drawino Control Records 3.2.1 Company Drawino Control Sheets (Enclosure #1) These control sheets will be naintained for each company drawing received at the l \,-) site. On this sheet is indicated the current information concerning dates, CFFICE EtiGII EERI!!G PROCEDURE NO. OEI-l quantities, distribution and filing infomation, of all revisions pertaining to that drawing. The appropriate rack number or numbers for the drawing will be indicated in the icwer right hand corner of that sheet. An asterisk and stamp stating approved for construction along with color highlighting will be used to indicate Approved for Construction drawings. 3.2.2 Vendor Drawino Control Sheets (Enclosure #2) A sheet will be maintained for each vendor drawing received at the site in the i same manner as the Company Drawing Control Sheets, except that only an asterisk will be used to indicate approved for construction. ~
, 3.2.3 Vendors Drawing Control Sheet for Contractor Field Drawinos, etc.
(See Enclosure #3) . This form serves the same function as the company drawing control sheet except - , that it is used for various contractor drawings and procedures. The fom provides i - for following the individual drawings and procedures through their approval stage as well as distributuion. 3.2.4 Vendor Eolodex Card or Control Sheet Files for Drawinos without Record fiumhers (See Enclosure ad) i i A card or c'ontrol sheet will also be maintained for each vendor drawing that is l not assigned a record number. Each drawing will be recorded by vendor 1 i drawing numbers, specification, structure or area and as a last resort by vendor name. All of these drawings are filed in a miscellaneous file by specification. 3.2.5 Vendors Drawino and Insoection l'anuals Record '(Enclosure #5) . On this fom is maintained all the information pertaining to vendors drawing and instruction manuals with cross references t'o the various identification numbers. The key feature of this fom is that it wiki be filid by type of equipment rather than numerical sequences. This provides a system that allows an engineer or inspector to locate drawings and/or manuals by type of eouipaent without requiring .kno11 edge of either record or drawings number.
OFFICE Ei; git lEERI;:G PROCEDURE NO. OEI-l W f} 3.2.6 Transmittal Forms 77G4 9/78 (Enclosure #6) and 62-5537 (Enclosure #G Form 77G4 9/78 will be used for transmitting all drawings, except "as-builts" to Engineering. Fom 02-5537 will be used to transmit "as-builts" to Engineering. 3.2.7 Daily List of flew and revised Drawines (Enclosure #7) y Each day the print room personnel will publish a listing of all company and vendor drawings received that day. This listing will also include sketches, and DCR's that constitute a drawing change. These company drawings received with a notation, " Approved for Construction,"
" Issued for Fabrication and Installation", " Approved for Planning and ftaterial Procurenent, "etc. will be noted with an asterisk on the listing.
3.2.8 Receival of Drawinas , All incoming drawings, specifications and manuals are to be delivered to the print room directly before any distribution is made. One copy of all sepias without
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prints received will be shown to respective departments to see if it is urgent. If urgent it will be reproduced imediately and ploced on the inspection table, otherwise it will be set aside to avait normal distribution from San Francisco. At the same time the balance of the drawings with sepias are being spread out on the
- layout table, sorted, counted and the date stamp placed on each one. Drawings i .
received from vendors and contractors will arrive with several copies of an engineering department transmittal attached (See Enclosure #8 for sample). This transmittal will have the vendor's name, purchase order number, record number, sheet number, and description on it. 3.3 Distribution and Filinn 3.3.1 Information vill be provided by the Resident Engineer regarding the nu.r.ber l of copies of company drawings to be provided each contractor. Company drawings which A
CFFICE Ef!GIllEERIfiG PROCEDURE fl0. OEI-1 are identified to be withheld from the contractor will not he distributed and a note to that effect will be transmitted to contractors on the job site when requested by the responsible Resident Engineer. A letter of transmittal (Fonn 77G4 9/78. Enclosure #6) will be made up for all drawings transmitted to contractors at their job site headquarters. An original and two copies of the transmittal are prepared, and third copy retained on file uhich serves as a basis for determining what transmittals have not been signed and returned. The third copy is destroyed when the signed transmittal is returned. The same system will be used for form 62-5537 (Enclosure #6A). 3.3.2 At the beginning of each week the Active File is to be checked for outstanding b transmittals that are unsigned for more than a week. A xerox cooy of these transmittals will be sent to the original addressee with a statement as follows: According to our records we have not received a signed copy of this form, due to loss or mix-up en route. Verification of receival is necessary to complete cur records. Please check your files and return (n) v this signed. Thank you for your cooperation. 3.3.3 Uhen drawings are received, the following steps are taken: A. They are date stamped. B. They are separated into four categories: Contractor, Rack, File and table copies. C. All are recorded on the control sheets. D. One cony of each will be placed on the racks provided for each category. l l All superseded drawings will be removed from filing cabinets and rac):s and de-stroyed, except the reproducible, which will be marked VOID - FOR REFEREf!CE ONLY and filed separately for possible future reference. In the event no reproducible A V -
OFFICE Ef:GIf1EEP.I!:G PROCEDURE NO. OEI-l is on file, a print will be kept. When all . superseded drawings are removed from files and racks, the ramaining new copies can be folded, marked with number and revision on the top right hand corner and filed. 3.3.4 For drawings received from vendors and contractors, a divider with the drawing number will be inserted between each new drawing in the file. All of these drawings will be filed behind the identifying divider. Void drawings will be processed as with company drawings. A print also will be retained for future reference if there is no reproducible available for that purpose. g 3.3.5 One copy of each approved drawing received each day will be placed on the provided inspection table for the information of company engineers and inspectors. All new drawings, drauing revisions, sketches, as-builts and DdR's received each day vill be listed on the DAILY LIST OF NEW AND REVISED DRAWINGS, which will be t j provided to each Resident Engineer, indicating what drawings have been received pertaining to their respective areas. After 48 hours, clock time, the drawings will be removed from the inspection table and placed in the file. 3.3.6 All drawings taken from the files will be signed for by the individual b requesting ,the drawings. This accounting record will be maintained on the out card filed with the drawings. It is the responsibility of the individual signing for the drawing to return same when requested or when he no longer has a use for the drawing. 3.3.7 Drawings issued as " sets" (i.e. piping schenatics, instrument schematics, electrical schematics and arrangements in 11" X 17" and 81/2" X 11" size), will be signed out as a set, and will te returned complete. (a) Distribution of the revisien will be made automatically to all P G and E personnel on record. (b) The processing of superseded drawings in these " sets" will be the responsibility of the respective t resident engineer. ID U
-s-
e 8 0FFICE ENGIriEERING PRDCEDUP.E tt0. OEI-1 3.4 Superseded Drawing Processing 3.4.1 In paragraph 3.3.3 it was stated that superseded drawings will be withdrawn from the siles and destroyed, exceRfor one reproducible marked VOID - FOR REFERENCE
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ONLY and retained for oossible future reference. Any drawings that have f'ield notes marked on them will be taken to the respective engineer / inspector to see if an "as-built" drawing is required, or whether the notes are worth saving. If the notes are to be kept, the drawings will be stamped and handled as above. 3.4.2 Uhen superseded drawings are removed from the file, the outcard will be checked f tn determine those individuals who are signed out with the superseded drawing. Drawing return forms (E0-24), Enclosure #9, listing applicable drawings will be issued to the , appropriate supervisor for action by the person named. (A duplicate copy will be kept on a suspense file in drawing control). ! (7 The signed OE-24, indicating the action taken, must be returned to Drawing Control within b 7 days of its issue date. 3.4.3 Upon receipt of the returned OE-24, drawing control personnel will take action i as follows: i 3.4.3.1 When drawings and the signed GE-24 are returned and the individual does not desire to retain the void drawings: Drawing control personnel will delete the l individuals name from the drawing "out card", correct the drawing control records and dispose of the void drawings, the suspense and signed OE-24. l 3.4.3.2 When drawings and the signed OE-24 are returned, and the individual desires l to retain the void drawings: Drawing control personnel.will stamp the drawings i VDID - FOR REFERENCE ONLY, indicate on the drawing "out card" that it has been retained by the individual, return the stamped drawing to the individual dispose of the suspense and signed CE-24. 3.4.3.3 When the signed OE-24 is returned, indicating that the drawings are not available for return: Drawing Control Personnel uill indicate on the drawing "out card" and the drawing control records, the reasons for their non-return, dispose of the
OFFICE ENGINEERIf!G PROCEDURE fl0. OEI-l
' suspense and signed OE-24 3.4.3.4 The drawing control OE-24 suspense file will be checked daily and notifications sent to the supervisors ref those individuals who are deliquent.
3.5 Drawina Audits 3.5.1 Drawing audits of all contractors, whose contract requires quality assurance, will be conducted weekly to verify that" their drawings are current. A ninimum of ten drawings for each contractor will be compared to the drawing control records (unless a contractor has less than 10 drawings then all drawings will be reviewed). The person conducting the audit will: 3.5.1.1 List the drawings which are reviewed by drawing and revision number on form CE-1, (" Enclosure #10) "On Job _ Drawing Inspection Report". The latest revision on the P G and E drawing control sheets shall also be listed.
'f%d 3.5.1.2 Any discrepancies shall be noted in the ccament section of the report.
3.5.1.3 Drawing audits shall be submitted to tne appropriate Resident Engineer for any corrective action necessary and subsequent distribution to the contractor and Quality Control. 3.5.2 Drawings maintained in the field by P G and E DRT, Instrumentation and Startup groups shall be compared to the drawing control sheets to verify that the drawings are current. A minimum of 10 drawings for each group, shall be reviewed each week. The person conducting the audit will: . (, 3.5.2.1 Same as paragraph 3.5.1.1 above except a Form OE-79 (Enclosure ell) will be used. . 3.5.2.2 Same as paragraph 3.5.1.2 above.
~
3.5.2.3 Drauing audits shall be submitted to the appropriate Resident Engineer for review and corrective action if applicable. l 1
OFFICE ErlGIrlEER!flG P:10CEDURE l10. OEI-l 3.6 Processinn of Sketches and/or Partial Channes l In order to expedite necessary design changes, or to make small changes in drauings, 81/2" X 11" Revision Sheets (sketches) will be utilized. . (See Enclosure 512 for sample). These sheets may be transmitted t'y company mail or, where expediency dictates, by telephone telecopier. OlABLO CANYON SKETCH # k
$NT. OF
- SK, N o. A$$lGNED ON 1177 3.6.1 Receival and Distribution (Figure 1) llhen a sketch, which constitues a drawing change, is received the Diablo Canyon sketch stamp (Fig.1) is applied. Before distribution is made. Then a sketch number' (indicating sequential sketch issuance) are assigned. Sketch numbers are logged on forn OE-2, Record of Sketches Changing Original Design Drawings, (Enclosure #13),
then distribution is made. Sketches will be distributed to all contractors who are recorded as having copies t ~ l of the drawing being affected by the change sketch, unless directed otherwise by the responsible Resident Engineer or his delegate. 3.6.2 As-Builts The changes to drawings or sketches showing "as-built" changes to be made to l other drawings uill be initiated by the Engineer or Inspector in charge of the individual structures or systens. They are responsible for making up the print with the proper color rencils, (grcen for deletions, red for additions), giving all dimensions and sufficient information to' adequately show the actual "as-built" l condition of the structure, system, equipment, -etc.."As-built" sketches are confined to 81/2" X 11" size xerox copies whenever possible. t! hen the Engineer or Inspector completes an "as-built" drawing, he will stamp l the sketch or drawing in red ink and fill out the blanks per the sample shown (m ) below, (Fig. 2), before turning it into the print roon for distribution. FIGt:RE f;0. 2
~
0' D'O Ct;N'(OM AC: BUi-DWGIb. 59 34~7 CJr.M/O uni p DATE 1-M ,I
-8
OFFICE EllGIffEERIt:G PROCEDURE fl0. OEI-l He will also indicate unit involved and Srief description of change. The print room will assign a sketch number (as described in paragraph 3.6.1) and reproduce the number of copies required for distribution. The city' copy will be given to the draftsman to be marked up in the same manner as the original. When the draftsman completes the changes to the copies, he returns them to the print room for distribution. . . Distribution of "as-built" sketches are made to engineering, originator and original to print room file, unless directed differently by the Resident Engineer or his delegate. In the case of extensive changes, where full sized drawings are marked up, only the original and one copy will be made. The original will be r,etained in the print room and the copy will be sent to the Engineering Department for incorpora- , tion on the next revision. O
- 3.6.3 Approval of Ot auing Changes Approval of drawing changes will be in accordance with GCR-9.
- When infomation is received that sketches are incorporated on newly revised drawings, t'he copy from the unincorporated files will be removed and maintained ,,
for a short period in the dead files. The sketch incorporation date will be entered on the OE-2 fom, Enclosure #13 (Fomerly Fom ES-2) 3.7 Process of Specifications, Lithograohic Sets and Addendums ,
; All specifications received will be accounte[f for on the specification and ,i -
i l _g_ O
f OFFICE ErlGIf!EERIflG PROCEDURE fl0. OEI-l
,O U revision Distribution Record (Enclosure #14). A specification will be filed in the Specification Correspondence file or assigned to an individual by initial. When , revisions are received they are issued to the appropriate holders. ' Specification Change Orders will be processed using the fom shown in Enclosure #15. Lithographic sets and addendums thereto will be processed as above using the fom shown in Enclosure il6.
3.8 Anerature Card Listina . This listing is provided on a biweekly and monthly basis by City Records Depart-ment. Upon receipt, the biweekly listing will be checked by the print room personnel to verify that we have received all the drawings and latest rev.isions listed. If there are any deviations noted, an appropriately marked xerox copy will be returned l to City Records Department for their action. l O. V ' 3.9 Information Only Drawina These drawings, either Vendor or Company, are sent to the contractor upon request from the Resident Engineer or one of his deiegates by use of Form OE-53 (Enclos-ure #17). They are sent to the contractors for their information only. If the drawing is requested on a one-time basis only, it will be stamped FOR IflFORMATIO!! OflLY: however, if contractor is on a regular distribution, the drawings will not be stamped. Subsequent changes to IflFO Of!LY drawings will not be sent to the contractor unless requested. All drawings in the contractor's possession marked FOR IriFOR;;ATICf! OflLY will not be subjected to audit by Company Personnel, since these
~
drawings so marked are not to be used for construction. In the case of Spec. 3802, Drawings that are issued for a specific job cn a "one time only basis, will'be marked "To De returned to P G and E upon completion of work" instead of infomation only. ' m
OFFICE EllGIflEERIllG PROCEDURE fiO. OEI-l bv 3.10 Uestinghouse Engineerina Change !!otice (ECfl) Upon submittal of an ECfl for approval, the original will be sent to Engineering Department for approval. 'When the ECN returns approved, it will be given to the respective Resident Engineer to read and sign. t!e will then return it to the print rnom for' distribution. 3.11 Cesign Change Recuests (PCR's) GCR-12 establishes the responsibilities and requirements for imolementirIg the use of DCR's. Drawing control is responsible for processing and control of DCR's. This will be accomplished as follows: 3.11.1 An on-site DCR log sheet (Enclosure #18) will be used to identify and control them, the same numbering system employed by engineering is established, except the letter following the V unit-identification will be "G" instead of "E". This numbering system has been established by the fluclear Project Engineer's office and consist of the following: Diablo Canyon Unit 1 DCl-1-(-001 Diablo Canyon Unit 2 DC2-G-E-002
+
Diablo Canyon Unit 1&2 DCO-G-f*-0 General Construction 8 l Civil Discipline-t I I Electrical Disciplinc' , t i Itechanical Discipline , Sequential fiumber From Site 3.11.2 Upon receipt of the DCR Drawing Control will check to insure that it has been signed by the appropriate Resident Engineer and it has the l OFFICE ENGINEERING PROCEDURE NO. OEI-l () necessary information. The next sequential number, with the appropriate discipline, will then be assigned and recorded on the log sheet (Enclosure
!19) and the DCR. The required copics will then be made and distributed and appropriate entries mace in the log. A DCR initiated by Engineering will be logged on Enclosure fl9, and appropriate distribution made.
l 3.11.3 Wnen the approved copy is returned to the site, the applicable log , l l entry will be made and appropriate distrubotion made. 3.12 Desian Chance Notices (DCN's) When a DCR has been reviewed, coordinated and signed, by the appropriate engineering discipline, it becomes a DCN. When a DCN is received the appropriate entries will be made in the applicable log sheets (Enclosure #16 or #17) and distribution made.. O e t t ( 1 I
OFFICE EllGI!;EERIfiG PROCEDURE fi0. OEI-l n 4.0 ATTACH!!EilTS E!1 CLOSURE flu" DER l COMPAfiY DRAUING C0flTROL SHEET (CE-7) 2 VEllDORS DRAWING CONTROL SHEET (DE-8) , 3 CONTRACTOR FIELD DPAWINGS MID PROCEDURES (CE-55) 4 VE!! DOR ROLODEX CARD FILES 5 VEftDORS DPAUI!!GS NiD If;STRUCTIO 111AfiUALS RECORD (OE-29) 6 TRNiSitITTAL FORil (77G4 9/78) 6a TPA!!SMITTAL F0PJ1 (62-5537) 7 DAILY LIST OF f!EU A';D REVISED DPAUIf!GS (OE-6)
~
8 ENGIf;EERIitG DEPART".Ef1T TRNISMITTAL 9 DRAWI!!G RETURN FORf1 (DE-24) t
) 10 Oil JOB DRAWIfiG If!SPECTI0f! REPORT (0E-1) 11 ON JOB DPAWIt:G INSPECTIO!! REPORT (DE-79)
. 12 SKETCH REVISIO!! SHEET 13 RECORD OF SKETCHES CHAflGING ORIGIt:AL DESIGN DPAWIf!GS (OE-2) 14 SPEC. N!D ADDEf1DUti DISTRIBUTIOil RECORD (OE-ll) 15 SPEC. CHNIGE ORDER DISTRIBUTI0fl (OE-12) 16 BID LITH 0 AND ADCE!1DU' DISTRICUTIOlI RECORD (OE-13) 17 REQUEST FOR ADDITIONAL DRANI!GS (0E-53) 1 18 DCR LOG SHEET .
l 19 CITY DCf! LOG SHEET 5.0 REFERE!!CES 5.1 Drawing Maintenance Procedure GCR-9 5.2 On-Site Drawing Control GCR-12 I __ -
- - . _ _ ~ ._. - - . - - - _ .__ . - - - . . . - . . - .
i .i 0FFICE ENGINEERING PROCEDURE NO. OEI-l
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j 6.0 CANCELLATION 1 ! 6.1- PACIFIC GAS AND ELECTRIC COMPANY Diablo Canyon Project Drawing Control i
- Procedure.
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E. EXPEDITED COPY u) O ADDITIONAL COPY OF EARLIER CHANGE REOUESTED A. ADVANCE V APPROVED FOR CONSTRUCTION P. PRELIMINARY a ISSUED FOR DID ggApfyg gg, N.O.S. NOT ON SITE
' 7. . __ _ . _ _ --
Co. Number Distribution To [ gg g g, g;,,,;gg,;,, \ "yojg " p,ggg,g, Ray Dale Copies of Contractor Rex Date Copies Spec. Copies copies Date Rec'd Rec'd p,;afs Copies Na File Rock Field Relobed Made , Trcns. Trans. No. Returned Oestroyed on fire
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N A. NOT APP'O Q REVISED A.O.S APP'D ON SITE ile APP'D FOR CONSTRUCTION A.S. APP'D AS TO SUBSTANCE C.F.C COPY FROf.1 CONTRACTOR A AGREES WITH CONTRACTOR COPY SN. SUBJECT TO NOTATION P. PRELIMINARY O. ADDITIONAL COPY R. REQUESTED Numbe Di ri " ' " I " VOID " Drawings Ven. Co. Von. ont octor R G.8 E. Oistrbutiwi 00f8 Copiss of. _ Rev Rox Rov. Oofo Copios
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Copies pf,0}l, o N2 N2 Date Afodo Trans. Trans. Destroyed (_ on Fola i l 1 . i DIABLO CANYON SITE D UNIT I GM 187027 O UNIT 2 GM IG9972 RECORD N O. TITLE: JOB NO. DWG. NO. CONTR ACT NO. MANUFACTURER m tosuas n s 7- ., - ?., . . r, - c . . . :,, ,., i c.a -,a e s, ., n i o n c, ,, o
O s APPROVED FOR CONSTRUCTION R.A.C.s RETURNED FOR ADDITIONAL CORRECTIONS R.
- REQUESTED S.N.s SUBJECT TO NOTATION O. s ADDIT!ONAL COPY A.S. APPROVED AS TO SUBSTANCE N.A.s NOT APPROVED ' R. S.
- REVISED & RESUBMITTED BY P.O. 8 E.
N O. cOPlE! DATE DISTRIBUTION TO PGSE VOID DESCRIPTION E N G R. CONTRACTOR DISTRIBUTION DRAWINGS REV DATE DATE COPIES OF T CHECKED
" COFIE5 PRINTS g OUT DATE COPIES SPEC. COPIES RETAIN.
N O. R E C' D. R EC' D. FILE RACK OTHER R E V* MADE APPL. APPROVAL FILE DUNIT/ GMI67027 DUNIT 2 GAf I69972 D/ABLO CA N YON SITE CONTRACTOR F/ ELD DRAIVINGS & PROCEDURES EHCLOS\lRE #3 STRUCTURE DRAIVING NO.
i 4 s DIA3LO CANYON HAULING UN.T Vende'rH [Vl . Dwa68-100-I-7/ STATOR GEN. TRAVEL AR?&CE'ENT BIGGE C?A?iE RIGGII:G SPEC. 8823
. Rev Date Rec'd l Quan i Distribution i / f-3-7D n-H-w B 2 % 9/e /-AW:
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e sa n.- r. PActrtC GAS AND El.kCTRIC COL 1PANY cv in FIE6 CORRECTICNS OF STATION DRAs JGS TRAtJSMITTAL TI [h a: GENERAL OFFICC. 71 f!EALE S.F CALIF. ATTE!sTION: O SuuSTATIONS DATE: i-7Y DEPT. OF ELECTRIC OPER. O HYDRO GENERATION GENERAL CONSTRUCTION O STEAM GENERATION O COMMUNICATIONS FROM:
, ' {JQ{ { DIVISION: A00F.ESS: Q@Q g -[g STATION: WO/G!.1 Otheck if none.
DRIEF DESCftlPTION On WORK DONE
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THE FOLLOWING CRAWINGS ARE FORWARDED FOR CORRECTION: C ange TITLE DRAWING NO. g 8-553' c1 0MeM d' VAL. COLITPcL - l
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l Received Received in Received By Receive,tj Dy , Tracing Approved New Prints Orcared Dept. Of Engr. Proiect Engr. Des. Draf ting BY BY BY SY SQD. BY DATE DATE DATE DATE DATE DATE ATPR. APPR. APPR. APPR- ENGR APPR. INSTRUCTIONS: Upon completion of job! immediately send in sufficient corrected drawings so that all related drawings can be correct ed. Complete (escription and nameplate data of sit egaespment instatted must be included. Upon completion and approval of all draweno correctinns. new prints weil be sDstribsted by the Engineereng Department. At thes time, one copy of this form will be returned to the Dives on Supermtendent involved. The
*11 tow.ng station drawings may be ef fectod: Single Lines. Etementary. Diagram of Connections. General Arrangements. Arrancement of Equipment. D.l:s
[ fRternat. Conduit Schadule. Circuit Schedulo. Draweng List. Oncription of Operations. Commun.cas.ons Drawings. Manuf acturers Uraw.ngs. l La more complete instructions see " Instructions to Fictd Personnel on Preparation of Drawing Markups Due to Field Changes - l A:tilable from the Design Draf ting Dep't. Elcet. G&T Unit. General Of fice.
' ' - ENCIDSUTI N CEMOVE SET FROM PAD DEFOr1C U LNG REMOVE YCLLOW COPY AND SEND WHITE AND PINet COPIC*. WIT >t CARnON INTACT.
WHiiE COPY WILL DC RETURNCD WHLN NEW PRINTO AHk ORDEf1ED.
r I ( ') NEW D AI LY AND LIST OF REVISED DR AWINGS GM- 169972 DATE 19_._ GM-lG7027 DR AWIN G [ A civil ELECTRIC Al. MECHANIC AL START-UP N D R AWINGS DRAWINGS D R AWINGS D RAWINGS N O.
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, l. I HAVE NOTED THE ABOVE AND HAVE PASSED IT bN TO MY ENGINEERS AND
! } INSPECTORS.
- 2. "THE ABOVE PROVIDED SPECS. APPLY TO THE REVISION NOTED ONLY.
ENCLOSURE #7
- 3. "ACCORDING TO SPEC. 8 PRC II, DOES THIS REQUIRE A APPROVAL STAMP ?
SIGNED: RESIDENT ENGINEER ne.c n o.. 7.90.77
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- 76-248' **' PAcir:C cAS AND ELECTRIC couPANY 1-7-70 = units 1 and 2 RECORD NUMBER DWG. LIST - MANUFACTURERS DRAWINGS
'.s e e Diablo conven 4R- 8700MROO Euu SPEC. 8700 A9800 SUPP'L IER Westinnhouse ENCR. tm S'e P-r.ECORD NO. bb3216 - DESCRIPTION _ Safety Injection System SYSTEM N.S.S.S. ,itt no, _140.090 DW G 's. EQUIPUENT ATT'D. S H.#REV STATUS D ATES MANUFACTURER DATE Q T Y. TITLE UFR. NO. R E Y. DIST R.
RECEIVED /-(/-7 3 3 2d2 9c 46 2- d Wastinghouse
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~ RETunNED SD-TCE/ PEG-200D / #3-I-73 RECEIVED //-/*I 7J 23 Illnifmim Flnw Orifice Annembly
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R EcEivE D 2-7-72. 2.15 - 0 3nduit Box Qutlinn for Safety In-4R / b i TUNNED lm WestinFhou'1e ]ection hittins C71-IS T / 4-/3-72. i l _~
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Acuimilator innk I;B 2E8) linit 2 41059-70-1 - ( - F 4/ AS!E Hrg. Data Report for SIS 53 i C* RE Tunorn
- Acumulator Tank NB 2690 6-FMe lin i t_2__ 41059-70-2 REcrivED d-2/ W l AStrri Mfe. Data Honort for SIS 54 I b RETughED Acumulator TanF. -~Ut1 2687 unit 2 41058-70-1 -
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- A RECEIVED N / 7 '4 2],,_,, 3J2ron In jection Flufdllpr' Orifice 55 /*C/ WWiiieTM p Westinghouse 2710150 W a j g< ..urc_EivtD ? ,1/-7 2, /0
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- REWRNFD r Ec EiviD 12 7 12/ > ><
Struthers Vell{ In_loction Tanks' Unit 2 ?Rtil Ud. 13345
- Start-Up Tant Procedure for Safety 59 1 C. TirunnED Westinghouso 12-2t. G Tnloction System 5.6.1 R EC ElvF D ID-31-N 11'E S1fety Iriection System Floir DiFrnr Sh 1 of 4 60 $ O_., iETunntD
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DIABLO C b PROJECT i DRAWING RETURN FORM Date (Issue Date) i . TO: Department Supervisor; (Civil), (Electrical), (Mechanical), (Startup), ('QC), (Cleanup Crew). I FOR ACTION BY i The following drawings you have checked out are VOID. , l (a) (b) (c) i Drawings I desire
! Drawing Nurr.ber & Returned to Retain Any Exceptions to Columns (a) & (b) (flote 3)
Revision to Drawing Drawings Control (flote2) * , (flote 1) g . , E . 3 . ! si i % 1 @ i .
. j i Hotes. 1. Drawings and sigried OE-24 must be returned to Drawing Control within 7 days of the OE-24 issue date.
2. l
' Drawings, as well as the signed OE-24 must be returned to Drawing Control.within 7 days of the OE-24 issue date. Drawing Control will affix the proper stamp to the drawings, make applicable record entries and issue the dr'tnng.
a , 3. Any exceptions to Columns (a) & (b) must be explained in Column (c) and the signed OE-24 returned to l Drawing Control within 7 days of its issue date. , l OE-24 (1-15-79) Signed
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\ J DIABLO NYON SITE UNIT NO. GM-ON JOB DRAWING ' INSPECTION REPORT DATE OF AUDIT CONTRACTOR SPECIFICATION P.G.a E. DRAWINGS CONTRACTOR DRAWINGS ON RK. O-OH CONTROt. SHTS.O ON FLO. RK O-ON OFF RK. O-OFF. RFc O CO. or DC DCor Vendor DC of Vendor DRAWING n DESCRIPTION t , e" ratYeif c9o REMARKS c,o nevrobI/or REMARKS DATE n NUMBER DI Ck nO7io D' 'k R.Dio
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